20250430Direct Anderson.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY' S APPLICATION FOR ) CASE NO. IPC-E-24-44
APPROVAL OF SPECIAL CONTRACT AND )
TARIFF SCHEDULE 28 TO PROVIDE )
ELECTRIC SERVICE TO MICRON IDAHO )
SEMICONDUCTOR MANUFACTURING )
(TRITON) LLC . )
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
GRANT T . ANDERSON

1 I . INTRODUCTION
2 Q. Please state your name and business address .
3 A. My name is Grant T. Anderson. My business
4 address is 1221 West Idaho Street, Boise, Idaho 83702 .
5 Q. By whom are you employed and in what capacity?
6 A. I am employed by Idaho Power Company ("Idaho
7 Power" or "Company") as the Pricing and Tariff
8 Administration Leader in the Regulatory Affairs Department.
9 Q. Please describe your educational and pre-Idaho
10 Power employment background.
11 A. In May of 2013, I received a Bachelor of
12 Science degree in Microbiology from Oregon State
13 University. In May of 2015, I earned a Master of Business
14 Administration degree from Boise State University. In March
15 2015, I accepted a role as a Corporate Development Analyst
16 for Albertsons, and in 2017, I was promoted to Corporate
17 Development Manager and served in this capacity until I
18 left Albertsons to join Idaho Power in 2018 . After joining
19 Idaho Power, I attended the electric utility ratemaking
20 course "Practical Regulatory Training for the Electric
21 Industry, " offered through New Mexico State University' s
22 Center for Public Utilities, and the "Utility Finance and
23 Accounting" course.
24 Q. Please describe your work experience with
25 Idaho Power.
ANDERSON, DI 2
Idaho Power Company

1 A. In 2018, I was hired as a Regulatory Analyst
2 in the Company' s Regulatory Affairs Department. My primary
3 responsibility as a Regulatory Analyst included supporting
4 the Company' s Commercial and Industrial customer classes'
5 rate design and general support of tariff rules and
6 regulations . In 2021, I was promoted to a Regulatory
7 Consultant and my responsibilities expanded to include the
8 development of complex cost-related studies, pricing
9 strategies, and the Company' s class cost-of-service
10 activities . In April of 2025, I was promoted to my current
11 position as Pricing and Tariff Administration Leader. My
12 primary responsibilities include management of the pricing
13 strategies of the Company, as well as oversight of all
14 tariff administration.
15 Q. What is the purpose of your testimony?
16 A. The purpose of my testimony is to explain how
17 the pricing components were developed for the Energy
18 Services Agreement ("ESA") for Micron Idaho Semiconductor
19 Manufacturing (Triton) LLC ("Micron") and its new memory
20 manufacturing complex ("Micron FAB") . Additionally, I will
21 present the no-harm analysis supporting that the ESA
22 provides sufficient mitigation against cost-shifting or
23 subsidies from existing customers .
24
25
ANDERSON, DI 3
Idaho Power Company

1 Q. Have you prepared any exhibits?
2 A. Yes . My testimony includes Confidential
3 Exhibit No . 1, presents the detailed results of the Micron
4 FAB No-Harm Analysis and is the same document filed as
5 Confidential Attachment No. 1 filed with the Company' s
6 comments filed on March 13, 2025, in this docket .
7 II . PRICING COMPONENTS
8 Q. What were the Company' s objectives in
9 developing the pricing for the Micron FAB?
10 A. The pricing structure in the ESA was designed
11 to ensure that Micron FAB pays rates that are cost-based,
12 transparent, and reflective of the impact its load has on
13 Idaho Power' s system. The structure includes demand charges
14 to recover Micron' s share of system capacity costs and a
15 marginal cost-based energy charge to serve the additional
16 load. The Company' s approach ensures that Micron
17 contributes appropriately to both existing and incremental
18 costs .
19 Importantly, the pricing framework is also
20 consistent with Idaho Power' s long-term planning outcomes .
21 The Company' s capacity expansion modeling, which is
22 described in the testimony of Company witness Jared L.
23 Ellsworth, shows that Micron FAB is being incorporated into
24 the system as part of broader resource needs . The pricing
25 and underlying cost allocation approach ensures that Micron
ANDERSON, DI 4
Idaho Power Company

1 picks up its fair and allocable share of existing and
2 incremental costs, without shifting additional cost burdens
3 onto other customers .
4 Q. What data did Micron provide to inform the
5 pricing derivation?
6 A. Micron was responsible for providing a load
7 forecast with monthly peak demand and energy requirements .
8 Q. Did the load forecast provided by Micron
9 change over time?
10 A. Yes . The forecasted load provided by Micron has
11 changed as the project has progressed. Recognizing that
12 forecasts may evolve but also considering the potential
13 impact of changes on the Company' s resource planning, the
14 ESA includes provisions to "lock in" specific levels of
15 Contract Demand and Minimum Billing Demand during the ramp
16 period once those levels are relied upon for firm resource
17 commitments . This mechanism provides certainty for system
18 planning and cost recovery, even if Micron' s actual usage
19 or future forecast updates later differs from its initial
20 forecast .
21 Q. Why is it important to lock in Contract Demand
22 and Minimum Billing Demand during the ramp period?
23 A. Due to the size and scale of the forecasted
24 load for the Micron FAB facility, locking in these demand
25 levels protects existing customers from potential cost
ANDERSON, DI 5
Idaho Power Company

1 shifting. Without such protection, if Idaho Power were to
2 make long-term resource procurements based on an initial
3 forecast and Micron later reduced its expected load, absent
4 other load growth taking that place, costs associated with
5 that investment could be disproportionately allocated to
6 other customers . The ESA mitigates this risk by limiting
7 Micron' s ability to revise its Scheduled Ramp Contract
8 Demand and Minimum Billing Demand after those levels are
9 used for resource procurement purposes . This protection
10 provides a strong basis for ensuring equitable cost
11 allocation in future rate proceedings and helps guard
12 against unintended subsidies .
13 Q. Please describe the pricing structure proposed
14 for the Micron FAB.
15 A. The pricing structure for the Micron FAB, as
16 defined in the ESA and Schedule 28, is intended to collect
17 Micron' s fixed capacity-related costs through demand
18 charges and its variable energy-related costs through
19 energy charges . The demand charges include a take-or-pay
20 Contract Demand Charge and a Billing Demand Charge, which
21 also includes a take-or-pay component that can be triggered
22 if Micron' s actual levels of demand are lower than the
23 contracted levels of Minimum Billing Demand.
24 Q. How were the proposed demand charges priced?
ANDERSON, DI 6
Idaho Power Company

1 A. Prices associated with the Contract Demand
2 Charge and Billing Demand Charge are based on embedded
3 system capacity costs following the cost-of-service
4 allocation methodology consistent with the Idaho Power 2023
5 General Rate Case ("GRC") Settlement Stipulation in Case
6 No . IPC-E-23-11 . This method is similarly aligned with the
7 Commission-reviewed approaches used in other recent special
8 contract agreements, including those for Brisbie and Lamb
9 Weston. '
10 The Company used the 2023 GRC test year as an
11 initial starting point. Similar to the approach used for
12 pricing Brisbie' s second block of load, Idaho Power
13 calculated Micron' s load ratio share of total system
14 demand-related capacity costs . For the Energy Charge, a
15 marginal cost-based methodology was applied, which I will
16 describe in more detail later in my testimony.
17 Q. Why was a load ratio share of embedded
18 capacity costs used to determine demand pricing?
19 A. The load ratio share approach was used to
20 ensure that Micron FAB pricing reflects its proportional
21 responsibility for Idaho Power' s fixed capacity-related
22 costs . This is consistent with traditional cost-of-service
23 principles and Commission precedent. The Company allocated
24 a share of embedded generation and transmission capacity
1 IPC-E-21-42 and IPC-E-23-18, respectively.
ANDERSON, DI 7
Idaho Power Company

1 costs based on the projected contribution for the Micron
2 FAB.
3 Q. How were rates developed after determining the
4 allocation method for the Micron FAB?
5 A. Once the proportional share of the revenue
6 requirement from the 2023 GRC was allocated to Micron FAB
7 based on its forecasted load, the resulting rates were
8 determined using the same methodology applied in the
9 Company' s cost-of-service study.
10 Q. Please describe the derivation of the Contract
11 Demand charge for Micron FAB?
12 A. Consistent with the method reviewed by the
13 Commission for special contract customers in Case No. IPC-
14 E-23-11, the Contract Demand rate for Micron FAB is based
15 on Idaho Power' s Open Access Transmission Tariff ("OATT")
16 rate effective October 1, 2022 . The OATT-based rate
17 represents the reservation cost that any other entity would
18 pay to reserve capacity on the Idaho Power system. It
19 provides a consistent, transparent, and equitable benchmark
20 for setting capacity-related charges in the ESA.
21 In the future, the Company anticipates this rate
22 will be updated to reflect changes in the OATT rate
23 consistent with other special contracts when a general rate
24 case or other rate proceeding results in an update to the
25 Contract Demand charge for those customers .
ANDERSON, DI 8
Idaho Power Company

1 Q. Please describe the derivation of the Billing
2 Demand Charge .
3 A. First, I determined the portion of the total
4 demand-allocated costs that will be collected through the
5 Contract Demand Charge. The remainder of the fixed
6 capacity-related costs are collected through a Billing
7 Demand Charge . This two-part structure allows for use of
8 the OATT-based rate to set the base level of collection
9 first and then deriving a Billing Demand charge to collect
10 the remainder of the special contract customer' s allocated
11 demand-related costs .
12 Q. Are these demand pricing components fixed for
13 the duration of the ESA?
14 A. No. The pricing components for all of Idaho
15 Power' s special contract customers - just like all customer
16 classes - will be updated over time, as authorized by the
17 Commission. In the specific case of the Micron FAB, as its
18 load ramps up and Idaho Power files future general rate
19 cases, or other rate proceedings, its cost allocation would
20 be updated to reflect those changes in system utilization,
21 and pricing would be updated accordingly. While the initial
22 pricing is derived based on the then-current approved
23 revenue requirement, future updates are expected to align
24 with evolving load levels and cost-of-service data similar
25 to any other customer class receiving pricing changes .
ANDERSON, DI 9
Idaho Power Company

1 Q. Please describe the energy pricing approach
2 used in the ESA.
3 A. The Energy Charge for Micron FAB is based on
4 the marginal cost of serving Micron FAB' s energy needs . The
5 marginal energy cost was derived by simulating the hourly
6 operation of the Company' s power supply system under
7 expected resources, streamflow conditions, and fuel prices
8 over the test year. The hourly marginal resource price is
9 determined based on the Company' s expected load plus an
10 incremental load increase. A weighted average marginal-cost
11 based rate is then calculated.
12 Q. Is this method consistent with the marginal
13 cost-based method used for other special contract customer
14 pricing?
15 A. Over the last several years, the Company has
16 refined its approach for determining marginal cost-based
17 prices . For example, in the Brisbie ESA, the Block 2
18 Supplemental Energy Price is based on the Avoided Cost
19 Averages published in Idaho Power' s most recently filed IRP
20 Technical Appendix C. Following execution of the Brisbie
21 ESA, Idaho Power had proposed to use the same basis for
22 marginal cost-based pricing in a separate case related to
23 establishing pricing for Schedule 20 in Case No . IPC-E-21-
24 37 . In Order No . 35428 issued in that case and in response
25 to a recommendation from Commission Staff, the Commission
ANDERSON, DI 10
Idaho Power Company

1 directed Idaho Power to evaluate and compare other methods
2 for determining a marginal cost of energy prior to filing
3 its next general rate case.
4 The Company and Staff were engaged in a series of
5 discussions to evaluate alternate methods to determining
6 the marginal cost of energy around the same time Idaho
7 Power and Lamb Weston were negotiating the Lamb Weston ESA.
8 As a result of those initial discussions, Staff issued a
9 memo dated February 16, 2023 ("Staff Memo") , where it
10 outlined several principles identified as best practices
11 that should be considered when evaluating marginal pricing
12 methodologies . Accordingly, the Block 2 Energy Charge
13 included in the Lamb Weston ESA reflected an updated method
14 consistent with those principles and relied on a simulation
15 of hourly operation of the Company' s power supply system
16 under expected resources, streamflow conditions, and fuel
17 prices for a test year. The method relied upon in the Lamb
18 Weston ESA leverages two model runs - one with a base level
19 of load and a second run inclusive of an additional 15 MW
20 of load. The Company refers to this approach as a "Two Run
21 Method. "
22 As it was negotiating the Micron ESA, the Company
23 became aware that the introduction of battery resources
24 into the model caused inaccurate and counterintuitive
25 marginal cost prices at the hourly level using the Two Run
ANDERSON, DI 11
Idaho Power Company

1 Method because the model dispatched the batteries
2 differently between the runs . Accordingly, Idaho Power held
3 additional discussions with Commission Staff to explain the
4 need for an updated methodology and to vet an updated
5 method, which the Company ultimately relied upon as the
6 basis for Micron' s marginal cost-based energy rates .2
7 This refinement provides an estimate of marginal
8 energy costs by leveraging AURORA' s capability to simulate
9 incremental cost effects at an hourly level . It ensures the
10 Energy Charge remains cost-based and responsive to current
11 system conditions .
12 Q. How does Idaho Power ensure that the Energy
13 Charge remains appropriate over time?
14 A. The ESA provides for annual filing updates to
15 the Energy Charge based on the proposed marginal cost
16 methodology. This allows the pricing to reflect changes in
17 fuel prices, market dynamics, hydro conditions, and other
18 planning variables that affect the Company' s cost to serve
19 the incremental energy needs . The annual update process
20 ensures that the Energy Charge remains aligned with cost-
2 See also In the Matter of Idaho Power Company's Application for its
Annual Update to Marginal Pricing Used in Certain Schedules, Case No.
IPC-E-25-17, Application (Apr. 1, 2025) (identifying the limitations of
the Two Run Method and introducing and proposing use of the Single Run
Method for determining the marginal energy cost-based energy price for
Schedule 20, Speculative High-Density Load) .
ANDERSON, DI 12
Idaho Power Company

1 causation principles through at least the scheduled ramp
2 period.3
3 Q. Did Idaho Power consider implementing a time-
4 of-use ("TOU") marginal cost pricing structure for Micron
5 FAB?
6 A. Yes, the Company evaluated the feasibility and
7 rationale of applying a TOU-based marginal cost pricing
8 structure for Micron FAB. However, it ultimately concluded
9 that TOU pricing was not appropriate or necessary under the
10 circumstances due to several key factors .
11 1 . High Load Factor: Micron FAB will operate with
12 a consistently high load factor, indicating a steady and
13 predictable energy consumption pattern throughout the day.
14 This uniform usage diminishes the potential benefits of TOU
15 pricing, which is designed to incentivize shifting energy
16 use from peak to off-peak periods .
17 2 . Limited Load Flexibility: The nature of Micron
18 FAB' s manufacturing processes allow for minimal flexibility
19 in adjusting energy usage in response to time-based price
20 signals . As a result, TOU pricing would not effectively
21 influence their consumption behavior.
3 After the scheduled ramp period ends, Micron has the option under the
ESA to request Idaho Power to reevaluate the basis for Energy Charges.
This provision was negotiated to allow an "offramp" for the
applicability of marginal cost-based energy prices, such that after the
scheduled ramp, the Company could consider pricing Micron FAB facility
at its then embedded variable energy costs.
ANDERSON, DI 13
Idaho Power Company

1 3 . Increased Complexity: Implementing TOU rates
2 would introduce complexity into the billing and pricing
3 design without delivering commensurate benefits . For a
4 customer with limited ability to respond to time-based
5 rates, this complexity is unwarranted.
6 While Idaho Power does not believe TOU pricing is
7 necessary in this case, the Company would not oppose such
8 an approach if the Commission determined it to be
9 appropriate . In that event, the TOU structure could be
10 designed to recover the same total cost as the current
11 flat-rate design, maintaining revenue neutrality due to
12 Micron FAB' s high load factor.
13 III . NO-HARM ANALYSIS
14 Q. Why did Idaho Power conduct a no-harm analysis
15 in connection with the Micron FAB ESA?
16 A. Idaho Power conducted a no-harm analysis to
17 demonstrate that the ESA pricing structure and underlying
18 methodology that was under consideration would not result
19 in inappropriate cost-shifting to existing customers . The
20 Company completed this analysis during contract
21 negotiations and prior to executing the ESA with Micron.
22 The analysis quantifies whether Micron FAB is sufficiently
23 allocated its share of both embedded and incremental system
24 costs and to confirm that other customers are not
ANDERSON, DI 14
Idaho Power Company

1 subsidizing the Micron FAB load. This analysis is included
2 with my testimony as Confidential Exhibit No. 1 .
3 Q. What methodology was used to conduct the no-
4 harm analysis?
5 A. The Company used AURORA' s Long-Term Capacity
6 Expansion model to compare two scenarios :
7 1 . A base case that includes Micron FAB load
8 ("With Micron") ; and
9 2 . A counterfactual case where the Micron FAB
10 load is removed, and the model re-optimizes the system
11 to meet remaining customer needs ("Without Micron") .
12 This approach provides a comparison of the system
13 costs and rate impacts to existing customers with and
14 without Micron FAB on the system.
15 Q. What timeframe and assumptions were used in
16 this analysis?
17 A. As more fully described in Mr. Ellsworth' s
18 testimony, the analysis was conducted using inputs and
19 planning assumptions from the 2023 IRP and relied on the
20 then-current forecast of Micron FAB' s expected load
21 profile .
22 Q. What were the results of the no-harm analysis?
23 A. The analysis showed that the cost to serve all
24 other customers was slightly lower in the scenario that
25 includes Micron FAB. This result confirms that the proposal
ANDERSON, DI 15
Idaho Power Company

1 to allocate a load ratio share of both embedded and future
2 system resources is not expected to cause rates to increase
3 for all other customers .
4 Q. Has Micron FAB' s expected load changed since
5 the analysis underlying the no-harm was completed?
6 A. Yes . After the Company conducted the analysis
7 for the two resource portfolios, the forecasted load provided
8 by Micron has changed as the project has progressed and the
9 expected load has increased.
10 Q. Has Idaho Power completed an updated no-harm
11 analysis based on changes to Micron' s load?
12 A. No. First, the nature of this type of
13 counterfactual analysis is based on a particular point in
14 time . Second, Idaho Power' s Planning team evaluated the
15 updated load and concluded that the existing IRP Preferred
16 Portfolio was still sufficient to meet system needs, even
17 with the increase in Micron FAB' s expected load. In other
18 words, the added load did not trigger the need for
19 additional near-term generation or transmission capacity
20 beyond what was already planned and therefore would not
21 result in increased cost pressure on other customers .
22 Q. If Idaho Power' s future resource portfolio
23 includes generation with higher marginal costs than those
24 modeled in the 2023 IRP Preferred Portfolio, wouldn' t that
ANDERSON, DI 16
Idaho Power Company

1 create upward pressure on system costs and potentially harm
2 existing customers?
3 A. The addition of higher-cost resources in the
4 future could increase overall system costs . However, this
5 does not result in Micron FAB avoiding its fair share of
6 those costs . The ESA does not permanently fix demand-
7 related pricing. Instead, it reflects cost responsibility
8 based on current forecasts and includes provisions that
9 allow for pricing to be updated over time — particularly
10 through future general rate cases .
11 Any new generation or transmission investments
12 brought forward through a Certificate of Public Convenience
13 and Necessity ("CPCN") , or other regulatory proceeding,
14 would ultimately be incorporated into Idaho Power' s revenue
15 requirement and cost-of-service studies . At that point, the
16 cost responsibility for those resources would be allocated
17 across all customer classes — including Micron FAB — based
18 on standard cost-of-service principles and Commission
19 decisions .
20 Therefore, if the Company adds higher-cost resources
21 in the future, Micron FAB will be subject to updated rates
22 that reflect its share of those costs . The ESA does not
23 insulate Micron from contributing to system growth-related
24 investment, and any capital recovery associated with new
ANDERSON, DI 17
Idaho Power Company

1 resources will be addressed through the same regulatory
2 process that applies to all customers .
3 Q. Is there a difference between the Micron FAB
4 rates included in Schedule 28 and what is assumed to be
5 collected in the no-harm analysis?
6 A. Yes . The rates included in Schedule 28 reflect
7 Commission-approved costs as of the Company' s change to
8 Idaho base rates from the 2023 general rate case, not
9 future projected costs . The nature of the no-harm analysis
10 assumes a general rate case every year, thus incorporating
11 growth in both generation and transmission costs each year
12 and re-allocating Micron its allocable load ratio share.
13 Schedule 28 will be subject to future Commission-
14 approved changes to demand revenue requirement beginning at
15 the time the Commission approves Schedule 28, including the
16 time the tariff is "on the shelf" before Micron FAB begins
17 taking service from Idaho Power under the ESA. This is
18 similar to what has occurred for other special contracts
19 which had Commission approved rates for when service would
20 later become effective under the applicable tariff
21 schedule .
22 Therefore, as new capacity-related generation and
23 transmission plant investment is added to rate base, it
24 would be allocated to customer classes through the
ANDERSON, DI 18
Idaho Power Company

1 respective general rate case or other ratemaking docket and
2 subject to Commission review and approval .
3 Q. Does the ESA include safeguards in the event
4 that Micron FAB' s load does not materialize as forecasted?
5 A. Yes . As described in Ms . Aschenbrenner' s
6 testimony, the ESA contains strong take-or-pay provisions,
7 including scheduled Contract Demand and Minimum Billing
8 Demand levels that guarantee a baseline level of cost
9 allocation and recovery. Additionally, as I previously
10 mentioned, Micron' s ability to revise its forecasted demand
11 is restricted during the scheduled ramp period, and the
12 agreement includes financial security provisions in the
13 event of early termination.
14 It is important to note that the Micron FAB ESA
15 includes the strongest customer protections the Company has
16 ever implemented for a special contract. Deliberate steps
17 were taken to mitigate risks by incorporating robust
18 customer safeguards into the special contract to protect
19 other retail customers from the potential for cost shifting
20 that could have otherwise resulted in the event Micron
21 reduces its forecast after the Company has already made a
22 commitment to invest in generation and transmission assets .
23 The approach encompassed in the Micron FAB special contract
24 ensures that future cost allocation in a general rate case
25 is allocated to the Micron FAB based on its load ratio
ANDERSON, DI 19
Idaho Power Company

1 share as anticipated within this ESA - not based on any
2 decreases to forecasted load that might occur later in the
3 scheduled ramp period.
4 IV. CONCLUSION
5 Q. Please summarize your testimony.
6 A. My testimony explains the methodology Idaho
7 Power used to develop pricing for the ESA with Micron FAB,
8 incorporating demand charges derived from a load ratio
9 share of embedded capacity costs and energy charges derived
10 from marginal cost simulations . These components ensure
11 cost-based, transparent pricing aligned with Commission
12 precedent .
13 I also present the results of a no-harm analysis,
14 included as Confidential Exhibit No. 1 to my testimony,
15 that shows Micron FAB' s rates do not result in
16 inappropriate cost-shifting or subsidization by other
17 customers . The ESA provides for future rate updates through
18 general rate cases and annual marginal cost revisions,
19 ensuring that Micron continues to pay its fair share of
20 system costs over time.
21 Q. What is your recommendation to the Commission?
22 A. I recommend that the Commission approve the
23 pricing components included in the Micron FAB ESA as just,
24 reasonable, and in the public interest, and find that the
ANDERSON, DI 20
Idaho Power Company

1 proposed rates are consistent with the principle of no harm
2 to existing customers .
3 Q. Does this complete your testimony?
4 A. Yes, it does .
5
ANDERSON, DI 21
Idaho Power Company

1 DECLARATION OF GRANT T. ANDERSON
2 I, Grant T . Anderson, declare under penalty of
3 perjury under the laws of the state of Idaho:
4 1 . My name is Grant T. Anderson. I am employed
5 by Idaho Power Company as the Pricing and Tariff
6 Administration Leader in the Regulatory Affairs Department
7 and am competent to be a witness in this proceeding.
8 2 . On behalf of Idaho Power, I present this
9 pre-filed direct testimony and exhibit in this matter.
10 3 . To the best of my knowledge, my pre-filed
11 direct testimony and exhibit are true and accurate.
12 I hereby declare that the above statement is true to
13 the best of my knowledge and belief, and that I understand
14 it is made for use as evidence before the Idaho Public
15 Utilities Commission and is subject to penalty for perjury.
16 SIGNED this 30th day of April 2025, at Boise, Idaho.
17
18 Signed:
19 rant T . Anderson
ANDERSON, DI 22
Idaho Power Company

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-44
IDAHO POWER COMPANY
ANDERSON , DI
TESTIMONY
CONFIDENTIAL
EXHIBIT NO. 1