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Home My WebLink About20210909IPC to Staff 12-16-Redacted.pdfLISA D. NORDSTROM Lead Counsel lnordstrom@idahopower.com September 9, 2021 VIA ELECTRONIC FILING Jan Noriyuki, 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-21-17 In the Matter of Idaho Power Company’s Application for Authority to Increase Its Rates for Electric Service to Recover Costs Associated with the Jim Bridger Power Plant Dear Ms. Noriyuki: Enclosed for electronic filing, pursuant to Order No. 35058, please find Idaho Power Company’s Response to the Second Production Request of the Commission Staff to Idaho Power Company. Due to the voluminous nature of 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. 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 was provided to all parties on July 21, 2021, and the login information for the confidential portion was provided to those parties that executed the Protective Agreement in this matter on July 21, 2021. The response to Production Request No. 16 contains confidential information. Idaho Power will transmit this to the Commission and parties that have signed the Protective Agreement separately via encrypted email. If you have any questions about the attached filing, please do not hesitate to contact me. Very truly yours, Lisa D. Nordstrom LDN:sg Enclosures RECEIVED 2021 SEP 9 PM 4:20 IDAHO PUBLIC UTILITIES COMMISSION IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 1 LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 lnordstrom@idahopower.com Attorney for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE IDAHO POWER COMPANY’S APPLICATION FOR AUTHORITY TO INCREASE ITS RATES FOR ELECTRIC SERVICE TO RECOVER COSTS ASSOCIATED WITH THE JIM BRIDGER PLANT ) ) ) ) ) ) ) CASE NO. IPC-E-21-17 IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to the Second Production Request of the Commission Staff (“Staff”) dated August 19, 2021, herewith submits the following information: IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 2 REQUEST NO. 12: In reference to the potential for one or more units of Jim Bridger being converted to natural gas, please respond to the following: a. Has Idaho Power performed an analysis on converting units of Jim Bridger to natural gas? Please explain and provide the analysis if performed; and b. How would the natural gas conversion of one or more units of Jim Bridger affect the Company’s proposed depreciation schedule, balancing account, and revenue requirement provided in this case? Please explain. RESPONSE TO REQUEST NO. 12: a. Idaho Power is performing an analysis on the conversion of Bridger units to natural gas as part of the 2021 Integrated Resource Plan. b. The potential conversion of one or more Bridger units to natural gas is an example of the fluid nature of the operating lives of the Bridger units. One of the benefits of the Company’s proposed balancing account mechanism is that it would allow for flexible timing and recovery of the remaining Bridger revenue requirement, including any expenditures associated with the conversion to natural gas, while also smoothing revenue requirement impacts and providing rate stability for customers. Idaho Power has proposed a depreciable life of year-end 2030 for all Bridger units. Should an integrated resource plan indicate that a conversion to natural gas with a later exit from Bridger would provide a more favorable economic outcome as compared to the proposed depreciable life assumption of 2030, the balancing account mechanism would allow for an update to the depreciable life and an adjustment to the IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 3 levelized revenue requirement, maintaining a relatively stable level of annual recovery even though an underlying cost driver changed. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 4 REQUEST NO. 13: In reference to State Implementation Plan (“SIP”) provided in Response to Staff’s Production Request No. 7. Please respond to the following: a. When was the SIP submitted to the U.S. Environmental Protection Agency; and b. Have Idaho Power and PacifiCorp been modeling the Voluntary Visibility Enhancing Emissions Limits discussed in the SIP in their Jim Bridger IRP analyses? If so, provide an explanation of the assumptions used in modeling the Voluntary Visibility Enhancing Emissions Limits, such as when the Limits would start. If not, explain why the Limits were not included. RESPONSE TO REQUEST NO. 13: a. The State of Wyoming submitted the State Implementation Plan (“SIP”) to the U.S. Environmental Protection Agency on May 14, 2020. b. Idaho Power is modeling the Voluntary Visibility Enhancing Emission Limits for Bridger in the 2021 IRP. Idaho Power worked with the plant engineering personnel to identify the estimated maximum generation available each month based on the voluntary emission limits (and yearly total maximum). Idaho Power’s share of the estimated maximum monthly generation starting on January 1, 2022, and modeled in the 2021 IRP is listed below: IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 5 Maximum Average MW January 587 February 587 March 587 April 587 May 619 June 649 July 649 August 649 September 649 October 629 November 629 December 587 The response to this Request is sponsored by John Carstensen, Joint Projects Leader, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 6 REQUEST NO. 14: Please provide a list of all assumptions used for each Bridger unit in the Company’s IRP modeling analysis. RESPONSE TO REQUEST NO. 14: The current Bridger unit modeling assumptions for the 2021 IRP that are also used in the quantification of the Bridger levelized revenue requirement are identical, with the exception of the two adjustments made in the levelized revenue requirement calculation discussed in Mr. Larkin’s testimony: (1) the inclusion of only interim future decommissioning costs and (2) the exclusion of large forecasted capital expenditures expected in 2028 and 2029. These cost assumptions were provided in the Confidential Attachment 1 to the Company’s Response to the Industrial Customers of Idaho Power’s Request No. 1. In addition, please see the Company’s Response to Staff’s Request No. 12 for a discussion of the potential natural gas conversion of the Bridger units. The final cost forecast/assumptions used in the 2021 IRP will consider the conversion of two units to natural gas. The response to this Request is sponsored by Randy Henderson, Principal Joint Projects Coordinator, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 7 REQUEST NO. 15: In reference to the file named “Request 1- CONFIDENTIAL Attachment 1- Exhibit No. 1 and workpapers – Bridger Levelized Rev Req” provided in Response to the Industrial Customers of Idaho Power’s First Production Request No. 1 as Confidential Attachment 1. Please explain the amount shown for Unit 3 capital expense for the year 2025 in the “Capex Forecast” tab. RESPONSE TO REQUEST NO. 15: There is no capital spend on Unit 3 in 2025 assumed in the forecast shown on the Capex Forecast tab. A major overhaul on Unit 3 is scheduled to occur in 2024. As described in Mr. Adelman’s testimony, a major overhaul of each unit is required every four years and entails repairs and upgrades on major components of the unit. If capital needs arise in 2025 for Unit 3 then the costs will be tracked and the Bridger levelized revenue requirement would be adjusted over time through the proposed balancing account mechanism to reflect any actual costs the Company incurs. The response to this Request is sponsored by John Carstensen, Joint Projects Leader, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 8 REQUEST NO. 16: In the Project Proposals provided in Response to Staff’s Production Request No. 9c, it states the work will be competitively bid to multiple contractors. Please explain the competitive bidding process, and provide copies of all competitive bids received and short-list/final bidding scoring for the following Appropriation Requests (“APR”): a. APR – 10007088, Project Title – Jim Bridger Unit 2 Turbine Upgrade High Pressure/Intermediate Pressure/Low Pressure; b. APR- 90000565, Project Title – Jim Bridger Unit 2 Turbine Upgrade High Pressure/Intermediate Pressure/Low Pressure; c. APR - 10015937, Project Title – U4 Absorber Reline 16; and d. APR - 90001005, Project Title – U4 Absorber Reline 16. RESPONSE TO REQUEST NO. 16: The following describes the competitive bidding used by the operating partner of Bridger, PacifiCorp: For all bids that are budgeted greater than $50,000, PacifiCorp uses an internet- based procurement tool for managing the Request for Proposal (“RFP”) process including the posting of RFP documents, collection of all correspondence and receipt of respondent proposals. All bidding information is highly confidential and collected through the internet in a sealed bidding process. If questions are asked by the bidders, the question and answer is provided to all bidders to ensure everyone receives the same information. If the project manager requests, a pre-bid meeting will be held at the plant-site so that bidders are familiar with the work environment and can gather information directly from the project manager and see the site where work is performed. Bids are due on a specific date. After receipt, the bids are reviewed and IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 9 analyzed technically by technical reviewers and reviewed commercially by procurement. The technical reviewers and procurement departments are comprised of both plant and corporate personnel. Bids of all levels are held confidential. Due to the voluminous nature of confidential and non-confidential information provided in response to previous data requests in this case, Idaho Power provided parties access to an FTP site where copies of all confidential and non-confidential responses can be found. The confidential attachments to this response can be found in the confidential portion of that site. a. APR-10007088 was the original APR and approved prior to identifying the need for blocking filters with this project. APR-90000565 was written and approved to include the costs for the turbine upgrade and blocking filters. This determination was made following the competitive bidding process and award for the turbine upgrade on Bridger Unit 1, The Review Record, provided as Confidential Attachment 1, reflects the competitive bid chain of approval on the initial purchase order for Unit 1. Confidential Attachment 2 is the Non- Competitive Procurement Justification Form specific to the Unit 2 upgrade. b. See response to a. c. APR-10015937 was originally written in January 2016 with the best estimate for the project. After further inspection of the unit, it was determined the IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 10 scope needed to be increased for the project to complete the repair and APR- 90001005 was written with the updated cost estimates. The Evaluation Matrix, included as Confidential Attachment 3 shows the results of the bid evaluations. Confidential Attachments 4 through 47 include the bid packages from the 5 contractors for the project. Idaho Power has separated the confidential bid packages by contractor into different folders on the FTP site. d. See response c. The response to this Request is sponsored by John Carstensen, Joint Projects Leader, Idaho Power Company. Respectfully submitted this 9th day of September 2021. LISA D. NORDSTROM Attorneys for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 11 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 9th day of September 2021, I served a true and correct copy IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Erick Shaner Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8, Suite 201-A (83714) PO Box 83720 Boise, ID 83720-0074 Hand Delivered U.S. Mail Overnight Mail FAX X Email: Erick.shaner@puc.idaho.gov _____ FTP Site Industrial Customer of Idaho Power Peter J. Richardson RICHARDSON ADAMS, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, Idaho 83707 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email peter@richardsonadams.com Dr. Don Reading 6070 Hill Road Boise, Idaho 83703 Hand Delivered U.S. Mail Overnight Mail FAX X EMAIL dreading@mindspring.com FTP Site Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 N. 6th Street Boise, Idaho 83701 Hand Delivered U.S. Mail Overnight Mail FAX X EMAIL botto@idahoconservation.org FTP Site City of Boise Ed Jewell 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 Hand Delivered U.S. Mail Overnight Mail FAX X EMAIL ejewell@cityofboise.org boiseCityAttorney@cityofboise.org FTP Site Hand Delivered IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - 12 Clean Energy Opportunities for Idaho, Inc. Kelsey Jae Law for Conscious Leadership 920 N. Clover Dr., Boise, Idaho 83703 U.S. Mail Overnight Mail FAX X EMAIL kelsey@kelseyjae.com FTP Site Michael Heckler Courtney White Clean Energy Opportunities for Idaho 3778 Plantation River Drive, Suite 102 Boise, ID 83703 Hand Delivered U.S. Mail Overnight Mail FAX X EMAIL mike@cleanenergyopportunities.com courtney@cleanenergyopportunities.com FTP Site Sierra Club Rose Monahan Ana Boyd 2101 Webster Street, Suite 1300 Oakland, CA 94612 Hand Delivered U.S. Mail Overnight Mail FAX X EMAIL rose.monahan@sierraclub.org ana.boyd@sierraclub.org FTP Site Micron Technology, Inc. Austin Rueschhoff Thorvald A. Nelson Austin W. Jensen Holland & Hart LLP 555 17th Street, Suite 3200 Denver, CO 80202 Hand Delivered U.S. Mail Overnight Mail FAX X EMAIL darueschhoff@hollandhart.com tnelson@hollandhart.com awjensen@hollandhart.com aclee@hollandhart.com glgarganoamari@hollandhart.com FTP Site Micron Technology, Inc. Jim Swier 8000 S. Federal Way Boise, ID 83707 Hand Delivered U.S. Mail Overnight Mail FAX X EMAIL jswier@micron.com FTP Site _____ __________________________ Stacy Gust, Regulatory Administrative Assistant BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16a ATTACHMENT NO. 1 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16a ATTACHMENT NO. 2 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 3 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 4 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 5 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 7 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 8 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 9 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 10 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 11 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 12 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 13 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 14 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO.15 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 16 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 17 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 18 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 19 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 20 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 21 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 22 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 23 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 24 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 25 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 26 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 27 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 28 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 29 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 30 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 31 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 32 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 33 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 34 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 35 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 36 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 37 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 38 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 39 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 40 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 41 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 42 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 43 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 44 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 45 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 46 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-17 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16c ATTACHMENT NO. 47