20101208IPC to Staff 21-33.pdf

LISA D. NORDSTROM
Lead Counsel
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esIDA~POR~
An IDACORP Company
December 7, 2010
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-10-25
IN THE MATTER OF THE APPLICA TlON OF IDAHO POWER COMPANY
FOR ACCEPTANCE OF ITS 2011 RETIREMENT BENEFITS PACKAGE
Dear Ms. Jewell:
Enclosed for filng please find an original and three (3) copies of Idaho Power
Company's Response to the Second Production Request ofthe Commission Staff to Idaho
Power Company in the above matter.
Also enclosed are four (4) copies each of non-confidential and confidential (included
in the confidential envelope) disks containing documents being produced in response to
Staffs Production Request. The confidential information should be handled in accordance
with the Protective Agreement executed in this matter.
Very truly yours,
oÇ~ß.n~~
Lisa D. Nordstro~
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.o. Box 70
Boise, ID 83707
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
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Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
ACCEPTANCE OF ITS 2011 )
RETIREMENT BENEFITS PACKAGE. )
)
)
)
)
)
CASE NO. IPC-E-10-25
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the Second Production Request of the Commission Staff to Idaho Power
Company dated November 29, 2010, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 21: In response to Staff Production Request NO.3 (b & c), the
Company states that "at this time, Idaho Powets employee retention is approximately
equivalent to that of industry peers." Please provide all analyses, including the retention
level or turnover ratios of Idaho Power and the industry peers, to support this statement.
RESPONSE TO REQUEST NO. 21: Please see pages 2 and 3 of the News
Release from the Bureau of Labor Statistics regarding turnover statistics provided on
the enclosed CD.
Turnover rates for employees leaving Idaho Power (not internal department
moves) are listed below:
Terminations
Voluntary and Involuntary terminations YTD
(excluding retirees)
Retirees
Total
41
25
66
Turnover Rate
Voluntary & Involuntary
Retirees
Total Rate
2.00%
1.20%
3.20%
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefits, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 22: In response to Staff Production Request No.5, the
Company states that "It should be noted that the level of risk borne by customers
between 2004 and 2010 resulted in significant customer benefits during those years in
that no customer costs related to the defined benefi plan occurred unti the spring of
2010. It is also important to recognize that the avoidance of risk may also mean
avoidance of any associated reward." Please identify any incremental benefit
customers received between 2004-2010 from the defined benefit pension plan. Please
also provide what is meant by "avoidance of any associated reward" as it pertains to
customers and the defined benefit pension plan.
RESPONSE TO REQUEST NO. 22: The Company has history going back at
least to 1976 regarding the market value of, the contributions to, and the distributions
from the pension plan trust fund. At the beginning of that time period, the trust had plan
assets with a market value of approximately $13 millon. As can be seen on the
schedule provided on the enclosed CD, during the time period 1976 through 2009,
inclusive, the Company made contributions to the plan of approximately $86 milion for a
total investment of less than $100 milion. During that same time period, the earnings of
the trust fund have permitted it to pay benefit payments and plan expenses of about
$305 millon while stil having an ending market value of $313 millon at December 31,
2009. Essentially (and expressed in nominal dollars), the Company has received more
than $600 millon in value from approximately $100 milion of contributions. This
performance would not have been possible without the assumption of some market risk.
The same dollars contributed, if invested at a risk free rate, would have resulted in a
much smaller value today. Had the Company sought to eliminate investment risk while
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
at the same time providing the same level of benefis to employees in order to remain
competitive, the cost to customers would almost certainly have been significantly higher.
This is what is meant by the phrase "avoidance of risk may also mean avoidance of any
associated reward."
The Company's intent in its response to Staffs Production Request NO.5 is to
point out that the growth in plan assets due to the assumption of market risk is precisely
the reason that the Commission, in Order No. 29505 and subsequent rate orders,
provides no current recovery of pension costs while, at the same time, the Company
has been able to provide a competitive benefit to its employees. The sentence from the
Company's response to Staffs Production Request No. 5 would probably have been
more clearly stated as follows, "It should be noted that the level of risk borne by
customers over the life of the plan resulted in significant customer benefits during the
years 2004 through 2010 in that no customer costs related to the defined benefit plan
occurred until the spring of 2010."
The response to this Request was prepared by Ken Petersen, Controller and
Corporate Chief Accounting Offcer, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO. 23: Please provide the amounts of pension expense included in
rates for each year between 1990-2010. Please separate the amounts by O&M
Expense and Capitalized Overhead in rate base. Please also provide the amounts the
Company contributed to the pension plan for the same time period.
RESPONSE TO REQUEST NO. 23: The requested information is included on
the schedule provided on the enclosed CD. The information is provided according to
the following three categories for each of the requested years:
1. The allowed pension expense recovery that was classified as O&M
expense based on the general rate case orders in effect during the respective time
periods. It should be noted that these amounts reflect the allowed pension expense
recovery and not actual recovery.
2. The estimated amount of pension expense capitalized to plant each
year. These amounts are calculated as a percentage of total annual FAS 87 pension
expense each year. The percentage is based on an estimated split of labor between
O&M and capitaL. These amounts do not represent amounts actually collected in rates.
-
Instead, they represent the amounts capitalized for future recovery through depreciation
and return on rate base. The capitalized pension expense amounts that are ultimately
included in rate base are embedded in the associated plant balances and are not
specifically tracked by the Company.
3. The Company's defined benefit plan cash contributions for each
year.
When comparing the allowed pension expense recovery to actual cash
contributions, it should be noted that the pension expense amounts that were allowed
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
for recovery from 1990 through May 2004 were based upon FAS 87 and not actual cash
contributions.
The response to this Request was prepared by Ken Petersen, Controller and
Corporate Chief Accounting Offcer, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST NO. 24: The analysis provided to Staff in response to Production
Request No. 12 uses an assumed 401 (k) contribution rate of 7% and a discount rate of
6.6%. Please provide the rationale for each of those two assumptions. Please also
provide copies of the ADP/ACP non-discrimination test for 2009.
RESPONSE TO REQUEST NO. 24: The discount rate of 6.6 percent is the
Company's current (as of December 1, 2010) effective interest rate or discount rate for
present value and actuarial calculations related to the Company's current defined
benefit pension plan. The 401 (k) contribution rate of 7 percent was the calculated
401 (k) contribution needed to result in a similar retirement benefi at retirement age
between the Company's current defined benefi pension plan and an alternative 401 (k)
plan for the average new hire, which currently is at an average age of 35 years old for
the Company.
Also, please see the copy of the ADP/ACP non-discrimination test for 2009
provided on the enclosed CD.
The response to this Request was prepared by Ken Petersen, Corporate
Controller and Chief Accounting Offcer, Idaho Power Company, in consultation with
Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COryMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST NO. 25: Please provide the complete report from Millman entitled
"Retirement Plan of Idaho Power Company Revised Actuary Report" using data as of
January 1, 2010.
RESPONSE TO REQUEST NO. 25: Please see the confidential report from
Milliman entitled "Retirement Plan of Idaho Power Company Actuary's Report -
Revised" using data as of Jsnuary 1, 2010, provided on the enclosed confidential CD.
Since this data is proprietary and a trade secret, Idaho Power is providing this
information only to parties that have executed the Protective Agreement.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefits, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
REQUEST NO. 26: Please explain how the Company wil experience savings in
2011 with the new pension plan formula, when the formula only applies to employees
who are hired after January 1, 2011, and the plan requires 12 consecutive months of
service before those employees wil be eligible to enter the plan.
RESPONSE TO REQUEST NO. 26: Although eligible employees must complete
12 months of consecutive service before they are eligible to participate in the pension
plan, those that remain employed through the first 12 months and continue on through
the 5-year vesting period receive credited service back to their original date of hire for
pension accrual purposes.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefits, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST NO. 27: In response to Production Request No. 17, the Company
states that other defined contribution plan formulas were evaluated. Please provide a
complete list of all defined contribution plan formulas that were evaluated during the
annual review and provide copies of that analysis.
RESPONSE TO REQUEST NO. 27: The Company evaluated three general
thematic changes to the Company's defined benefit plan:
1. Increases to the Company's matching formula on employee 401 (k)
accounts.
2. Increasing the Company's matching formula with employee
seniority, so that a more generous matching formula is available as employees
approach retirement.
3. Reduce the annual defined benefit pension accrual for all
employees and add an additional Company contribution to each employee's 401 (k)
account to compensate for the reduced pension accruaL.
As stated in the Company's response to Staffs Production Request No. 17, the
maximum 401 (k) vesting allowed by law is three years for cliff vesting and six years for
graded vesting. After these vesting periods are fulfiled, both employer and employee
contributions are fully portable by the employee should he/she leave the Company. As
a result of these inherent legal limitations, which limit the employee retention capabilities
of a defined contribution plan, evaluation one generally increases Company costs
without providing additional employee retention potentiaL. Evaluation two proved
inconsistent with the purpose of a 401(k) plan, which is to incent employee savings
early in their careers to take full advantage of compound returns throughout a career.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -10
Evaluation three prompted the Company to request Miliman to generate an analysis
combining a 1.2 percent annual pension accrual factor for new and existing employees,
with a 1 percent additional Company contribution to each employee's 401 (k) account. A
summary of Miliman's analysis is provided on the enclosed confidential CD. Since this
data is proprietary and a trade secret, Idaho Power is providing this information only to
parties that have executed the Protective Agreement. Evaluation three was ultimately
dismissed, as the resulting benefit level was not competitive and the cost savings were
modest.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefits, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST NO. 28: In response to Production Request No. 20, the Company
states that the executive management team reviewed the "Annual Retirement Benefits
Review Summary" provided on the enclosed CD. The enclosed CD did not include this
summary. Please provide a copy of the summary.
RESPONSE TO REQUEST NO. 28: The Company's response to Staffs
Production Request No. 20 provided the redacted Annual Retirement Benefits Review
Summary on the non-confidential CD labeled IPCO's Responses to Staffs Production
Requests Nos. 11, 12, 13 & 20. For Staffs convenience, the report is provided again on
the enclosed non-confidential CD.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefis, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
REQUEST NO. 29: In Idaho Power's response to the Industrial Customers of
Idaho Power (ICIP) Production Request NO.1 (c & d), the Company states that "Of the
92 energy services companies in the Towers Watson database, 66 companies, or 72
percent, have defined benefit pension programs available to new salaried employees.
Thirty-six percent of these are traditional defined benefi plans similar to Idaho Powets.
Twenty-six of the 92 energy service companies, or 28 percent, have defined
contributions plans as the sole source for retirement savings." Please provide the
underlying information that supports these statistics.
RESPONSE TO REQUEST NO. 29: The Company-specific data gathered by
Towers Watson is not in the Company's possession and is proprietary and confidential
to Towers and Watson. Towers Watson has provided the names of energy services
companies currently in its database and provided the statistics previously provided to
the Industrial Customers of Idaho Power. Although Towers Watson could not confirm
the same companies were used for its earlier analysis, according to Towers Watson, it
is likely that only a few may have changed.
Allant Energy Corporation
Ameren Corporation
American Electric Power System
American Water
ATC Management Inc.
Atmos Energy Corporation
Avista Corporation
Basin Electric Power Cooperative
Black Hils Corporation
California Independent System Operator Corporation
Calpine Corporation
CenterPoint Energy, Inc.
Central Maine Power
Connecticut Natural Gas
Consolidated Edison Company of New York, Inc.
Constellation Energy Group, Inc.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -13
Consumers Energy Company
CPS Energy
The Dayton Power & Light Company
DCP Midstream, LP
DTE Energy
Duquesne Light Holdings, Inc.
E.ON U.S. LLC
Electric Reliabilty Council of Texas, Inc.
EI Paso Corporation
EI Paso Electric Company
The Empire District Electric Company
Enbridge Energy Partners, L.P.
Energy Future Holdings Corp.
Energy Northwest
Entergy Corporation
Equitable Resources, Inc.
FirstEnergy Corp.
FPL Group, Inc.
Georgia Power Company
Great Plains Energy Inc.
Hawaiian Electric Company, Inc.
Idaho Power Company
Indianapolis Power & Light Company
Integrys Energy Group, Inc.
ISO New England
Keyspan Energy
Kinder Morgan, Inc.
Lower Colorado River Authority
Madison Gas and Electric Company
MDU Resources Group, Inc.
Midwest ISO
Minnesota Power
National Grid
New York State Electric & Gas Corp.
Northeast Utilties Service Company
NorthWestern Energy
NSTAR
NV Energy
NYISO
OGE Energy Corporation
Orange & Rockland Utilties, Inc.
Orlando Utilties Commission
Otter Tail Power Company
Pacific Gas and Electric Company
PacifiCorp
Pinnacle West Capital Corporation
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
PJM Interconnection
PNM Resources, Inc.
Portland General Electric Company
Potomac Electric Power Company
PPL
Progress Energy, Inc.
Public Service Enterprise Group
Puget Sound Energy, Inc.
Rochester Gas and Electric Corporation
Salt River Project
San Diego Gas & Electric Company
SCANA Corporation
Sempra Energy
Southern California Edison
Southern California Gas Company
Southern Company Services, Inc.
The Southern Connecticut Gas Company
Southern Union Company
STP Nuclear Operating Company
SunCoke Energy, Inc.
TECO Energy, Inc.
Tennessee Valley Authority
Tucson Electric Power Company
The United Iluminating Company
Uniti Corporation
Vectren Corporation
We Energies
Westar Energy, Inc.
The Wiliams Companies, Inc.
Wolf Creek Nuclear Operating Corporation
Xcel Energy Inc.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefis, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15
REQUEST NO. 30: In Idaho Powets response to the Industrial Customers of
Idaho Power (ICIP) Production Request No.2 (c & d), the Company states that "of the
12 peer companies selected for a custom analysis, 8 companies, or 67 percent have
defined benefit pension programs available to new salaried employees. Fifty percent of
these are traditional defined plans similar to Idaho Powets. Four of the 12 energy
service companies, or 33 percent, have defined contribution plans as the sole source for
retirement savings." Please provide the underlying information that supports these
statistics.
RESPONSE TO REQUEST NO. 30: Company-specific data gathered by Towers
Watson and included in its Employee Benefits Information Center database is not in the
Company's possession and is proprietary and confidential to Towers Watson.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefits, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
REQUEST NO. 31: In Idaho Powets response to the Industrial Customers of
Idaho Power (ICIP) Production Request No. 9 (a), the Company states that "Mr.
Anderson's instructions to Ms. Gerschultz detailed on page 5, lines 14 through 22, of his
Direct Testimony and Ms. Gerschultz's execution of those instructions demonstrates
that shareowner liabilties are an important consideration in the annual review process
and ultimately helped to shape the modified package structure." The referenced lines in
Mr. Anderson's Direct Testimony reads "I asked her to make recommendations for
changes to the Company's retirement benefits package based upon the Company's
desire to remain competitive to the representative employment market, but with an eye
toward perpetuating a package which encourages employee retention. i encouraged
her to recognize that retirement benefit portabilty is not in alignment with the
Company's employee retention goals and may not be in the best interests of
customers." Please explain how Mr. Anderson's instructions and Ms. Gerschultz's
execution of those instructions demonstrate how shareholder liabilties are an important
consideration in the annual review process. In responding to this question, please note
that the Company's response to Commission Staff's Production Request NO.5 where
the Company acknowledges that all market risk associated by the defined benefit plan
is ultimately borne by customers.
RESPONSE TO REQUEST NO. 31: Idaho Powets response to the Industrial
Customers of Idaho Power's Production Request No. 9 points out that Idaho Power's
shareowner risk or liabilty associated with the defined benefi plan is not market risk,
but rather regulatory risk or cost recovery risk. Under the current regulatory framework,
Idaho Power is allowed an opportunity to recover its prudently incurred expenses
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -17
through rates. Mr. Anderson's instructions to Ms. Gerschultz and Ms. Gerschultz's
execution of those instructions is reflective of the Company's efforts to prudently
manage its cost of providing retirement benefits, thereby mitigating its cost recovery
risk. The Company believes that shareowners should not bear any market risk
associated with its retirement benefits package. The Company further believes that the
2011 Retirement Benefis Package properly balances the risk/reward equation for
employees, shareowners, and customers.
The response to this Request was prepared by Greg Said, General Manager of
Regulatory Affairs, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -18
REQUEST NO. 32: Please identify any of the 92 energy services companies
that serve under the jurisdiction of the Idaho Public Utilities Commission. Please
provide the percentage of a new salaried employee's base pay that is attributable to
retirement benefits for these companies.
RESPONSE TO REQUEST NO. 32: The energy services companies that Idaho
Power is aware of that serve under the jurisdiction of the Idaho Public Utilties
Commission are: Avista, Idaho Power Company, MDU Resources, and PacifiCorp.
Company-specific data such as the percentage of a new salaried employee's base pay
that is attributable to retirement benefits for these companies is not in the Company's
possession and is proprietary and confidential to Towers Watson.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefits, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19
REQUEST NO. 33: Please provide the dates of all changes made to the
retirement package since inception and explain those changes.
RESPONSE TO REQUEST NO. 33: Please see the table summarizing the
substantive historical Retirement Package information with dates and changes identified
provided on the enclosed CD.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefis, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, this ih day of December 2010.
æ. lJ. 't /dLISA D. NORD ROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this th day of December 2010 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-- Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email Weldon.StutzmanCcpuc.idaho.gov
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email peterCcrichardsonandoleary.com
gregCcrichardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates
6070 Hil Road
Boise, Idaho 83703
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email dreadingCcmindspring.com
ik£1.';~¡s D~ordstrom
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTIÒN
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21