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HomeMy WebLinkAbout20130820IPC to Staff 11-24.pdf3Iffi*. An IDACORP ComDanv ?-tll SUE l! Fil S: 00 LISA D. NORDSTROM Lead Gounsel I nordstrom@idahopower.com August 19,2013 VIA HAND DELIVERY Jean D. Jewell, Secretary ldaho Public Utilities Commission 472 West Washington Street Boise, ldaho 83702 Re: Case No. IPC-E-13-16 Certificate for Public Convenience and NecessityforJim Bridger Units 3 and 4 - ldaho Power Company's Response to the Second Production Request of the Commission Staff Dear Ms. Jewell: Enclosed for filing in the above matter are an original and three (3) copies of ldaho Power Company's Response to the Second Production Request of the Commission Staff ("Staff') to ldaho Power Company. Also, enclosed are four (4) copies each of a non-confidential and confidential disk containing information responsive to the Staffs Second Production Request. Please handle the confidential information in accordance with the Protective Agreement executed in this matter. Sincerely, lr:' ';;-* '.- ',,':t! !i-; ,i' . .t ,; r I l;-l I i=.--- ,X, -044tu Lisa D. Nordstrom LDN:csb Enclosures 1221 W. ldaho St. (83702) P.O. Box 70 8oise, lD 83707 LISA D. NORDSTROM (lSB No. 5733) JENNIFER M. REINHARDT-TESSMER (lSB No. 7432) Idaho Power Company 1221West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 I no rd strom@ ida hopower. com irei n hardt@ ida hopower. co m Attorneys for ldaho Power Company IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE INVESTMENT IN SELECTIVE CATALYTIC REDUCTION CONTROLS ON JIM BRIDGER UNITS 3 AND 4. l;1IJ 5: l0 CASE NO. IPC-E-13-16 IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compotry"), and in response to the Second Production Request of the Commission Staff ("Staff') to ldaho Power Company dated July 29, 2013, 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. 11: Please reference Direct Testimony of Michael J. Youngblood, p.16, lines 3-15. Please provide all analyses, assumptions, workpapers and worksheets (in electronic form with formulas intact) that result in the calculation of the revenue requirement of approximately $9.1 million and $9.7 million for Jim Bridger Units 3 and 4, respectively. RESPONSE TO REQUEST NO. 11: Please see the attached Excel file containing the requested analyses and workpapers. The response to this Request was prepared by Michael J. Youngblood, Manager of Regulatory Projects, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 REQUEST NO. 12: lf not provided in response to Request No. 11, please provide the analyses, assumptions, workpapers and worksheets (in electronic form with formulas intact) that calculate the depreciation expense and accumulated depreciation used in the calculation of the revenue requirements referenced in Mr. Youngblood's testimony. Please include within your response the capital investment (commitment estimate) by electric plant in service account number and the associated depreciation rate for each plant account. RESPONSE TO REQUEST NO. 12: The capital investment included in the high- level system revenue requirement calculation is $62,923,527 for the Selective Catalytic Reduction ("SCR") controls on Jim Bridger Unit 3 and $66,913,866 for the SCR controls on Jim Bridger Unit 4. This plant investment would be included in Federal Energy Regulatory Commission Accounts 310-316. Please see the Excel file provided in the Company's response to Staffs Production Request No. 11. The response to this Request was prepared by Michael J. Youngblood, Manager of Regulatory Projects, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 REQUEST NO. 13: lf the depreciation rates in response to Request No. 12 do not match the most recently Commission-authorized rates, please provide all studies, life cycle analyses and other information used to derive the depreciable lives of the plant additions. Please provide this information for each electric plant in service account. RESPONSE TO REQUEST NO. 13: The depreciation rates used in the high- level system revenue requirement calculation match the rates included in the most recent depreciation study approved by the ldaho Public Utilities Commission ("Commission") in Order No. 32559. Because the revenue requirement calculation was a very high-level estimate, the Company used the average depreciation rate for the Jim Bridger power plant to calculate depreciation expense. Please see the Excel file provided in the Company's response to Staffs Production Request No. 11. The response to this Request was prepared by Michael J. Youngblood, Manager of Regulatory Projects, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 REQUEST NO. 14: lf not provided in response to Request No. 11, please provide the analyses, assumptions, workpapers and worksheets (in electronic form with formulas intact) that identify the jurisdictional allocation factors (reference Application, page 8, item 17). Please include within your response a comparison of these allocations to those approved within the Company's last general rate case. lf the allocations used in the revenue requirement analysis prepared for this case do not match those used in the last general rate case, please identify in detail the differences and the reasoning underlying each difference. RESPONSE TO REQUEST NO. 14: For the high-level system revenue requirement analysis, the Company utilized the D10 allocation factor from the jurisdictional separation study used in the Company's last general rate case (Case No. IPC-E-11-08) to allocate the SCR plant investment to the ldaho jurisdiction. Please see the Excel file provided in the Company's response to Staffs Production Request No. 11. The response to this Request was prepared by Michael J. Youngblood, Manager of Regulatory Projects, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counse!, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 REQUEST NO. 15: Please provide all analyses, assumptions, workpapers and worksheets (in electronic form with formulas intact) that result in the calculation of the almost $12 million of Allowance for Funds Used During Construction (AFUDC) included within Mr. Youngblood's testimony. Reference Direct Testimony of Michael J. Youngblood, p.15, line 9. RESPONSE TO REQUEST NO. 15: Please see the attached Excel file for the requested information. The response to this Request was prepared by Mitch McClellan, Joint Venture Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.6 REQUEST NO. 16: lf the response to Request No. 15 includes a cash flow and AFUDC rate (in percentage) calculation, please identify how the cash flows per month were identified and/or forecasted and provide all supporting documentation associated with those amounts if not already provided. Please include within your response the accounting extracts for amounts incurred to date and all electronic files with formulas intact. RESPONSE TO REQUEST NO. 16: Please see the Excel file provided in the Company's response to Staffs Production Request No. 15. Cash flows were forecasted by the plant operator, PacifiCorp. ldaho Power used a straight-line approach for allocating annualforecasted amounts on a monthly basis. The response to this Request was prepared by Mitch McClellan, Joint Venture Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counse!, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7 REQUEST NO. 17: Please provide the actual AFUDC monthly rate calculations for July 2O1O through July 2013. Please include within your response the documentation supporting those calculations and any review and analyses performed on them. RESPONSE TO REQUEST NO. 17: Please see the confidentia! Excel file provided on the confidential CD and the attached non-confidential Excel file. The support for the balances used in the AFUDC calculation is voluminous. Therefore, ldaho Power will make it available for viewing at its corporate headquarters in Boise, ldaho, to parties that have signed the Protective Agreement in this matter. Please contact Doug Jones at 388-2615 or Camilla Victoria at 388-5821 to view the materials. The confidential CD will be provided to those parties that have executed the Protective Agreement in this matter. The response to this Request was prepared by Mark Annis, Financial Reporting & Accounting Research Manager, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counse!, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8 REQUEST NO. 18: Please describe how the project will be financed. Please include within your response a summary of the payment schedule that will be followed. Please also provide within your response copies of any financing agreements. RESPONSE TO REQUEST NO. 18: ldaho Power expects to finance this project consistent with the financing of its total construction program. The Company expects to finance its capital requirements with a combination of intemally generated funds and externally financed capital. ldaho Power has not entered into any alternative financing agreements and therefore has not developed a financing payment schedule based on non-traditional financing schemes. The response to this Request was prepared by Randall Henderson, Finance Team Leader ll, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counse!, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9 REQUEST NO. 19: Please provide copies of the minutes of all ldaho Power Board of Directors' meetings (and committee and/or subcommittee meetings) at which the Project was discussed. Please provide within your response all analyses, presentations and any other materials that may have been provided to the Board of Directors and comm ittee and/or subcomm ittees. RESPONSE TO REQUEST NO. 19: Board Minutes. The ldaho Power Board of Directors' ("Board") Minutes reflect that investment in the SCR controls at Jim Bridger Units 3 and 4 ("Project") was discussed at the following Board meetings: March 16, 2011 (educational meeting); January 19,2012 (full Board meeting); March 20,2013 (educational meeting); and May 15, 2013 (educational meeting). Excerpts from the Minutes of the referenced Board meetings which pertain to the Projectl are provided on the confidentia! CD (Attachment 1). Copies of the full Board Minutes are available for review by the Commission Staff at ldaho Power's corporate headquarters upon request. Chief Executive Officer ("CEO") Letters. Beginning in May 2012, the Project was also referenced in several of the Idaho Power CEO letters that are provided to the Board each month. Excerpts from the monthly CEO letters that address the Project are provided on the confidentia! CD (Attachment 2). Copies of the full CEO letters which reference the Project are available for review by the Commission Staff at ldaho Power's corporate headquarters upon request. Annual Budoets. The Board also approved ldaho Power's current and projected expenditures for the Project through its approval of ldaho Power's annual budgets for 1 The Minutes of the May 15, 2013, Board meeting are in draft form until approved by the Board at its next meeting, which is scheduled for September 19, 2013. The Minutes are subject to change until approved by the Board. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1O 2010-2013. Further information regarding said budget approvals is included in the attachments provided in the Company's response to Staffs Production Request No. 20. The confidential CD will be provided to those parties that have executed the Protective Agreement in this matter. The response to this Request was prepared by Patrick A. Harrington, Corporate Secretary, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counse!, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11 REQUEST NO. 20: Has the ldaho Power Board of Directors authorized expenditure of funds for construction of the Project? lf so, what amount has been authorized? Please include within your response the details of the amount authorized and, if it differs from the amount included within the Company's Application, why it differs. RESPONSE TO REQUEST NO. 20: ldaho Power's Board has authorized the expenditure of funds for construction of the Project through the Board's approval of ldaho Power's annual capital budgets for 2010-2013, as set forth below. 2010 Capital Budqet Approval. The Board approved the ldaho Power 2O1O capital budget through the following resolution adopted on November 19, 2009: RESOLVED, That the 2010 capital budget in substantially the form presented to this meeting be, and it hereby is, approved, and the proper officers of the Company are hereby authorized to take any and all action they deem necessary to effect the 2010 capital budget. The Board's approva! of the 2O1O capita! budget was based on the "2010 O&M and Capital Budgets Summary" presented at the Board's November 19, 2009, meeting. A copy of the portions of the "2010 O&M and Capital Budgets Summary" which pertain to the Project is provided on the confidentia! CD (Attachment 1). A copy of the full "2010 O&M and Capital Budgets Summary" is available for review by the Commission Staff at ldaho Powe/s corporate headquarters upon request. 2011 Capita! Budqet Approval. The Board approved the ldaho Power 2011 capital budget through the following resolution adopted on January 20,2011: RESOLVED, That the 2011 capital budget in substantially the form presented to this meeting be, and it hereby is, approved, and the proper officers of the Company are IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12 hereby authorized to take any and all action they deem necessary to effect the 2011 capital budget. The Board's approval of the 2011 capital budget was based on the "2011 O&M and Capital Budgets Summary" presented at the Board's January 20,2011, meeting. A copy of the portions of the "2011 O&M and Capital Budgets Summary" which pertain to the Project is provided on the confidential CD (Attachment 2). A copy of the full "2O11 O&M and Capital Budgets Summary" is available for review by the Commission Staff at ldaho Power's corporate headquarters upon request. 2012 Caoital Budoet Approva!. The Board approved the ldaho Power 2012 capital budget through the following resolution adopted on January 19,2012: RESOLVED, That the 2012 capital budget in substantially the form presented to this meeting be, and it hereby is, approved, and the officers of the Company are hereby authorized to take any and all actions as they deem necessary or desirable to effect the 2012 capital budget. The Board's approval of the 2012 capita! budget was based on the "2012 O&M and Capita! Budgets Summary" presented at the Board's January 19,2012, meeting. A copy of the portions of the "2012 O&M and Capital Budgets Summary" which pertain to the Project is provided on the confidential CD (Attachment 3). A copy of the full "2012 O&M and Capital Budgets Summary" is available for review by the Commission Staff at ldaho Power's corporate headquarters upon request. 2013 Capital Budoet Approval. The Board approved the ldaho Power 2013 capita! budget through the following resolution adopted on January 17,2013: RESOLVED, That the 2013 capital budget in substantially the form presented to this meeting be, and it hereby is, approved, and the officers of the Company are hereby authorized to take any and all actions as they deem necessary or desirable to effect the 2013 capital budget. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13 The Board's approval of the 2013 capital budget was based on the "2013 O&M and Capital Budgets Summary" presented at the Board's January 17,2013, meeting. A copy of the portions of the "2013 O&M and Capital Budgets Summary" which pertain to the Project is provided on the confidential CD (Attachment 4). A copy of the full "2013 O&M and Capital Budgets Summary" is available for review by the Commission Staff at ldaho Power's corporate headquarters upon request. Page 49 of the "2013 O&M and Capital Budgets Summary" provided on the confidential CD lists total projected expenditures for "Bridger-Selective Catalytic Reduction-All Units" as $218,034,000 for the 2013-2022 budget period. Application Commitment Estimate ldaho Power's Application states on page 7: V. COMMITMENT ESTIMATE 14. As Mr. Youngblood describes in his direct testimony, the total cost of the Project before Allowance for Funds Used During Construction (.AFUDC") is $353,843,886. Idaho Power's share of that amount, the "Project Cost," is one- third, or $117,947,962, comprised of a $57,649,1 13 investment in Jim Bridger Unit 3 and a $60,298,849 investment in Jim Bridger Unit 4, before AFUDC. Confidential Exhibit No. 7 to Mr. Youngblood's direct testimony shows the budget projections by year for Jim Bridger Units 3 and 4. (Emphasis added.) ldaho Powe/s Commitment Estimate of $1 17,947,962 for the Project is less than the $218,034,000 authorized budget expenditure level for "Bridger-Selective Catalytic Reduction-All Units" as shown in confidentia! Attachment 4. However, the $117,947,962 Commitment Estimate set forth in ldaho Power's Application applies only to the SCR improvements at Jim Bridger Units 3 and 4, while the $218,034,000 budget figure applies to SCR improvements for all four Jim Bridger units over the 10-year IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14 budget planning period. ldaho Power considers the Board's authorized budget expenditure of $218,034,000 for Jim Bridger power plant SCR improvements for all Jim Bridger units through 2022 to be sufficient to cover the $1 17,947,962 Commitment Estimate set forth in the Application for SCR improvements to Jim Bridger Units 3 and 4. Furthermore, Board authorization for Jim Bridger SCR expenditures can be adjusted in future year budget approvals as deemed appropriate by the Board. The confidential CD will be provided to those parties that have executed the Protective Agreement in this matter. The response to this Request was prepared by Patrick A. Harrington, Corporate Secretary, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15 REQUEST NO. 21: lf not already provided in response to Staff Production Request No. 1, please provide copies of all contracts, leases, option agreements and memorandums of understanding signed to date for engineering, procurement, construction, major equipment, permits, and any other documents needed to complete the Project. RESPONSE TO REQUEST NO. 21: The requested additional contracts, leases, option agreements, and memorandums of understanding signed to date for engineering, procurement, construction, major equipment, permits, and any other documents needed to complete the Project are voluminous. Therefore, Idaho Power will make them available for viewing at its corporate headquarters in Boise, ldaho, to parties that have signed the Protective Agreement in this matter. PIease contact Doug Jones at 388- 2615 or Camilla Victoria at 388-5821 to view the materials. The response to this Request was prepared by Tom Harvey, Joint Projects Manager, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16 REQUEST NO. 22: Please identify the amounts of non-refundable expense, investment and contractual obligations to date associated with the Project. RESPONSE TO REQUEST NO. 22: As of July 31 ,2013,ldaho Powe/s share of the investment that has been capitalized to construction work in progress is $1,496,424.22, including AFUDC. A complete estimate of contractual obligations to date, including any penalties that may apply for early termination, necessarily requires a legal analysis. Therefore, ldaho Power objects to Staff's Production Request No. 22 on that basis. Notwithstanding this objection, ldaho Power refers Staff to the subject engineering, procurement, and construction contract, which is available for viewing at ldaho Powe/s corporate headquarters in Boise, Idaho, by those parties that have signed the Protective Agreement in this matter. The sponsors of this answer are John Carstensen, Engineering Project Leader, and Mitch McClellan, Joint Venture Analyst, of ldaho Power. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17 REQUEST NO. 23: Please provide an unredacted copy of the Report and Order from the Public Service Commission of Utah, issued May 10,2013 for Docket No. 12- 035-92. Reference the Company's Application, Attachment 2. RESPONSE TO REQUEST NO. 23: The Company was not a party in Docket No. 12-035-92; therefore, it does not possess the unredacted copy of the Report and Orderfrom the Public Service Commission of Utah issued on May 10,2013. The response to this Request was prepared by Kelley K. Noe, Regulatory Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 18 REQUEST NO. 24: Please provide a detailed analysis of any differences between the project costs contained on pages 33 and 34 of the unredacted Report and Order from the Public Service Commission of Utah, issued May 10,2013 for Docket No. 12-035-92 and the total project costs contained in the Company's Application. RESPONSE TO REQUEST NO. 24: Please see the Company's response to Staffs Production Request No. 23. The response to this Request was prepared by Kelley K. Noe, Regulatory Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, ldaho Power Company. DATED at Boise, ldaho, this 19th day of August 2013. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. 19 LISA'D. NORDS Attorney for ldaho Power Company CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 19th day of August 2013 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 Kristine A. Sasser Deputy Attorney General ldaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, ldaho 83720-007 4 Overnight Mail FAXX Email kris.sasser@puc.idaho.qov lndustrial Gustomers of ldaho Power Hand Delivered Hand Delivered U.S. Mail _U.S. Mail _Overnight Mail FAX Peter J. Richardson Gregory M. Adams RICHARDSON ADAMS, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, ldaho 83707 Dr. Don Reading 6070 Hill Road Boise, ldaho 83703 ldaho Conseruation League Benjamin J. Otto ldaho Conservation League 710 North Sixth Street Boise, ldaho 83702 Snake River Alliance Dean J. Miller Chas. F. McDevitt Celeste K. Miller McDEVITT & MILLER LLP 420 West Bannock Street P.O. Box 2564 Boise, ldaho 83701 X Emai! peter@richardsonadams.com oreq@richardsonadams.com Hand Delivered U.S. Mai! Overnight Mail FAXX Email dreading@mindsprinq.com Hand Delivered U.S. Mail Overnight Mail FAXX Email botto@idahoconservation.org Hand Delivered U.S. Mail Overnight Mail FAXX Email ioe@mcdevitt-miller.com chas@ mcdevitt-mil ler. com ck@ mcdevitt-miller. co m IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20 Ken Miller, Clean Energy Program Director Snake River Alliance P.O. Box 1731 Boise, ldaho 83701 Hand Delivered U.S. Mail Overnight Mail FAXX Email kmiller@snakeriveralliance.orq Christa Bearry, Legal Assistant IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21 CERTIFICATE OF ATTORNEY ASSERTION THAT MATERIALS REQUESTED AND PROVIDED DURING THE COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PROCEEDING ARE PROTECTED FROM PUBLIC INSPECTION Case No. IPC-E-I3-16 The undersigned attomey, in accordance with RP 233, hereby certifies that the attachments provided in ldaho Power Company's responses to the Idaho Public Utilities Commission Staffs Request for Production Nos. 17 (Attachment 2), 19, and 20 contain information that is a trade secret or privileged or confidential as described in ldaho Code S 9-340, ef seg., and $ 48-801, ef seg., and as such are exempt from public inspection, examination, or copying. DATED this 19h day of August 2013. Counselfor ldaho