20220902IPC to ICL 1-21.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
September 2, 2022
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-22-22
In the Matter of Idaho Power Company’s Application to Complete the Study
Review Phase of the Comprehensive Study of Costs and Benefits of On-
Site Customer Generation & For Authority to Implement Changes to
Schedules 6, 8 and 84 for Non-Legacy Systems
Dear Ms. Noriyuki:
Attached for electronic filing is Idaho Power Company’s Response to the First
Production Request to the Idaho Conservation League in the above-referenced matter.
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 will be provided to
all parties, while the login information for the confidential portion will only be provided to
those parties who have executed the Protective Agreement in this matter.
If you have any questions about the documents referenced above, please do not
hesitate to contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:sg
Attachments
RECEIVED
2022 SEP-2 PM 2:24
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-22-22
Idaho Power Company’s Application to Complete the Study Review Phase of the
Comprehensive Study of Costs and Benefits of On-Site Customer Generation &
For Authority to Implement Changes to Schedules 6, 8, and 84 for Non-Legacy
Systems

The undersigned attorney, in accordance with RP 67, believes that the
Attachments in response to Request Nos. 1, 8 and 9 to Idaho Power Company’s
Response to the First Production Request of Idaho Conservation League dated
September 2, 2022, may contain information that Idaho Power Company or a third party
claims is confidential as described in Idaho Code § 74-101, et seq., and § 48-801, et
seq., and as such is exempt from public inspection, examination, or copying.

DATED this 2nd day of September 2022.

Lisa D. Nordstrom
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 1
LISA D. NORDSTROM (ISB No. 5733)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION TO
COMPLETE THE STUDY REVIEW
PHASE OF THE COMPREHENSIVE
STUDY OF COSTS AND BENEFITS OF
ON-SITE CUSTOMER GENERATION &
FOR AUTHORITY TO IMPLEMENT
CHANGES TO SCHEDULES 6, 8, AND
84 FOR NON-LEGACY SYSTEMS

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CASE NO. IPC-E-22-22

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
IDAHO CONSERVATION LEAGUE
TO IDAHO POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of Idaho Conservation League (“ICL”) dated
August 12, 2022, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 1: Please provide the following natural gas
price forecasts discussed at page 105 of Idaho Power Company’s (IPC) 2021 Integrated
Resource Plan (2021 IRP):
a. Platts’ 2021 Henry Hub long-term forecast, after applying a basis differential
and transportation costs from Sumas, Washington.
b. The EIA Low Oil & Gas Supply forecast from the Energy Information
Administration’s Annual Energy Outlook 2021.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
a. Please see the confidential attachment for the requested data.
b. Please see the webpage for the Energy Information Administration’s (“EIA”)
Annual Energy Outlook 2021 at: U.S. Energy Information Administration - EIA
- Independent Statistics and Analysis.1
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

1 https://www.eia.gov/outlooks/archive/aeo21/
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 2: If IPC has a more recent gas price
forecast than used in the 2021 IRP, please provide it. Also, if IPC used a different gas
price forecast for the VODER study than the 2021 IRP forecast, please provide that
forecast.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Idaho Power used the
same natural gas price forecast for the VODER Study (“Study”) as was used in the 2021
Integrated Resource Plan (“IRP”). Idaho Power does not have a more recent natural gas
price forecast available to share.
The natural gas price forecast will be revisited as part of the 2023 IRP, and the
Company will use an updated forecast in the 2023 IRP analysis.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 4
REQUEST FOR PRODUCTION NO. 3: Please provide the gas transportation
rates assumed in the gas forecast in page 106 of the 2021 IRP:
a. The rates that were applied for transportation from Stanfield, and the years in
which they apply (i.e. what were any discounted rate and the years in which
they apply, and what were any full tariff rates and the years they apply).
b. Please provide the basis differential assumed in each year for Stanfield, or at
whatever point commodity gas supplies are transported from, versus the
benchmark Henry Hub market.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: As stated on page 106 of
the 2021 IRP, the rate is $1.39/MMBtu. Idaho Power would only potentially require the
expansion of the Northwest Pipeline from the Rocky Mountain supply region to Idaho for
natural gas generating projects beyond an incremental 600 megawatts (“MW”) of
capacity, which never occurred in any of the 2021 IRP portfolios. As such, these costs
were never applied in the 2021 IRP.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 4: Please provide the annual (nominal $/ton)
values for the 2021 Carbon Price Forecasts (the High Carbon Case/SCC and the
Planning Case) shown in Figure 9.3 of the 2021 IRP.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: For the carbon price
forecasts used in the 2021 IRP, please see the following table:
2021 IRP Carbon Price Forecasts $/ton
Yea
Planning Carbon
Case - CEC Low
Price
High Carbon
Case/SCC
Low Carbon Case -
Zero Carbon
2021 $52.56
2022 $54.48
2023 $20.41 $56.93 $0.00
2024 $21.98 $59.42 $0.00
2025 $23.65 $61.92 $0.00
2026 $25.41 $64.40 $0.00
2027 $27.27 $66.89 $0.00
2028 $29.26 $69.43 $0.00
2029 $31.41 $72.07 $0.00
2030 $33.72 $74.78 $0.00
2031 $36.19 $77.56 $0.00
2032 $38.83 $80.39 $0.00
2033 $41.64 $83.26 $0.00
2034 $44.65 $86.20 $0.00
2035 $47.88 $89.22 $0.00
2036 $51.35 $92.33 $0.00
2037 $55.08 $95.52 $0.00
2038 $59.08 $98.80 $0.00
2039 $63.36 $102.17 $0.00
2040 $67.95 $105.61 $0.00
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 5: Appendix 4.3 of the VODER study
provides Energy Imbalance Market (EIM) locational marginal prices (LMPs), in the EIM
markets administered by the California Independent System Operator (CAISO).
a. Are these the CAISO LMPs for the “ELAP_IPCO-APND” node
b. Please explain why they appear to be significantly lower than the LMPs posted
on the CAISO OASIS site for that node (i.e. for 8/1/21 Hour 1, $35.53 per MWh
VODER value vs. $62.7 per MWh for the ELAP_IPCO-APND node).
c. Are the “Date” and “hour ending” values in Pacific or Mountain time? For
example, is the price of $35.53 per MWh for 8/1/2021 Hour 1 labeled in terms
of Pacific Standard Time (PST) or Mountain Standard Time (MST)?
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the following
responses regarding Appendix 4.3 of the Study:
a. The prices in Appendix 4.3 are the published CAISO Hourly Load Aggregation
Point (“LAP”) prices for the “ELAP_IPCO-APND” node used in the CAISO real
time market (“RTM”). This price node is an aggregate of the fifteen and five-
minute RTM prices.
b. As noted in response to Request No. 5a, the price node used in the Study was
the CAISO Hourly “ELAP_IPCO-APND" aggregated node. The $62.70 per
megawatt-hour (“MWh”) price published by CAISO is the day-ahead market
(“DAM”) price. Please see Figure 1 and Figure 2 for a screenshot from the
CAISO OASIS site. In Figure 1, the HE01 RTM price is $35.53, which was used
in the Study. In Figure 2, the HE01 DAM price is $62.70.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 7
Figure 1
Hourly RTM LAP Price

Figure 2
Hourly DAM LAP Price

c. The prices included in Appendix 4.3 of the Study are in Pacific Prevailing Time
(“PPT”). This means that they are noted in either Pacific Standard Time (“PST”)
or Pacific Daylight Time (“PDT”), adjusted for daylight savings time. Please
note that the Company provided revised appendices in response to Clean
Energy Opportunities for Idaho (“CEO”) Request No. 2.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 8
REQUEST FOR PRODUCTION NO. 6: Regarding IPC hourly loads:
a. Please provide FERC Form 714 data for 2021.
b. Please explain why FERC Form 714 data for 2020 shows different loads than
in the VODER study Appendix 4.10. For example, total load is 1,557 MW for
1/1/20, Hour 1, in the VODER study appendix, whereas it is 1,743 MW in FERC
Form 714 for Idaho Power (Respondent ID = 180). Are the two datasets
comparable?
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Please see the following
responses regarding Idaho Power hourly loads:
a. Please see the attachment for the FERC Form 714 data for calendar year 2021.
b. The referenced data utilized in the VODER study shows different loads than
the FERC Form 714 because the two datasets are not comparable. FERC
Form 714 covers all generation assigned to the Idaho Power balancing
authority area and actual interchange with other balancing authority areas to
determine the net energy for load in the Idaho Power balancing authority area.
The data provided for the Study only contains Idaho Power native load.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 9
REQUEST FOR PRODUCTION NO. 7: Regarding IPC annual peak hourly loads
in 2020:
 FERC Form 1, page 401b, for 2020 indicates a maximum hourly load of
3,723 MW, occurring on August 18, 2020, hour 20.
 Form 714 for 2020 shows an annual peak of 3,723 MW, occurring on August
18, 2020, hour 18 (MST).
 The VODER study, appendix 4.10, shows 2020 peak load equal to 3,392
MW, occurring at on August 18, 2020, hour 17.
 FERC Form 1, page 400, indicates that the 2020 transmission system peak
loads shown below occurred on August 18, 2020, hour 17.
August 2020 Idaho Power
Company Transmission
System Peak Load (MW)
Peak MW
Firm
Network
Service
for Self
Firm
Network
Service for
Others
Long-Term
Firm Point-to-
point
Reservations
Short-Term
Firm Point-
to-point
Reservation
4,695 3,064 341 973 363

a. In FERC Form 1, was the maximum load of 3,723 MW reported on page 401b
computed as the approximate sum of 3,064 MW firm network service for self,
341 MW firm network service for others, and 317 MW short-term firm point-to-
point reservation (i.e. 3,723 ~= 3,064 + 341 + 317)?
b. Please explain why the 3,392 MW system peak load listed in the VODER study
differs from the 2020 peak loads indicated in FERC Form 1 and FERC Form
714.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
a. As a point of clarification, the FERC Form 1 (page 401b) does not indicate a
maximum hourly load of 3,723 MW for 2020. As shown in Figure 3 below, the
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 10
2020 FERC Form 1 shows a peak load of 3,392 MW reported on page 401b
(occurring on August 18, 2020) which is consistent with the value provided in
the Study.
Figure 3
FERC Form 1, page 401b

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 11
b. As partially explained in response to Request No. 6, FERC Form 714 data
encompasses the load in the Idaho Power balancing authority area. In contrast,
the data utilized in the Study contains only Idaho Power native load, so it is
expected that the system peak load values would differ. As noted in response
to Request No. 7a, the 2020 FERC Form 1 shows the same peak load of 3,392
MW as the Study.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 12
REQUEST FOR PRODUCTION NO. 8: Please provide the IPC’s most recent
forecast of future transmission system investments (i.e. additions to plant in service as
reported on page 206 of FERC Form 1 in FERC Accounts 350-359), by year, for the future
period over which IPC plans such investments. To the extent available, this information
should include:
a. A list of transmission lines and substations planned to be added or upgraded,
their voltage level, and the principal reason for each addition or upgrade.
b. The expected capital cost and in-service date of each planned transmission
addition or upgrade.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Please see the
confidential attachment for this response. At Idaho Power only a single year’s plan is an
approved budget amount. Therefore, the Company has provided the annual forecasted
amounts for years beyond 2022 that have not been approved by the Company’s
management and Board of Directors.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 13
REQUEST FOR PRODUCTION NO. 9: Please provide IPC’s most recent forecast
of future distribution system investments (i.e. additions to plant in service as reported on
page 206 of FERC Form 1 in FERC Accounts 360-374), by year, for the future period
over which the IPC plans such investments. To the extent available, this information
should include:
a. A list of distribution circuits and substations planned to be added or upgraded,
their voltage level, and the principal reason for each addition or upgrade.
b. The expected capital cost and in-service date of each planned transmission
addition or upgrade.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Please see the
confidential attachment for this response. At Idaho Power only a single year’s plan is an
approved budget amount. Therefore, the Company has provided the annual forecasted
amounts for years beyond 2022 that have not been approved by the Company’s
management and Board of Directors.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 14
REQUEST FOR PRODUCTION NO. 10: Provide the IPC’s most recent forecast
of future annual system peak loads, as reported in FERC Form 1, page 401b, over the
same forecast period as the T&D investment forecasts in Requests 8 and 9.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Please see the
attachment for Idaho Power’s most recent forecast of future annual system peak loads
over the same forecast period as the T&D investment forecast.
The response to this Request is sponsored by Jordan Prassinos, Load Research
and Forecasting Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 15
REQUEST FOR PRODUCTION NO. 11: Please provide the IPC’s most recent
forecast of transmission system peak loads, as reported in FERC Form 1, page 400, over
the same forecast period as the T&D investment forecasts in Requests 8 and 9, if those
peak loads differ from the system peak loads requested in Request 10.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: The Company does not
forecast transmission system peak loads in a manner consistent with the information
reported on FERC Form 1, page 400.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 16
REQUEST FOR PRODUCTION NO. 12: Please provide 8,760 hourly substation
loads for a recent calendar year (e.g. 2020 or 2021) in Excel spreadsheet format for each
of IPC’s Idaho distribution substations. For each substation, please also provide its
maximum capacity. Note: IPC has previously provided such data for 2016 in response to
a Sierra Club data request in Docket IPC-E-17-13.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Please see the
attachment for this response. This 2020 hourly load raw data was downloaded from Idaho
Power’s data historian for 204 substations. The data for substations serving less than 15
customers was redacted to maintain customer confidentiality.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 17
REQUEST FOR PRODUCTION NO. 13: Please provide 8,760 hourly substation
loads for a recent calendar year (e.g. 2020 or 2021) in Excel spreadsheet format for each
of the IPC’s Idaho transmission substations. Please also include, for each substation, its
maximum capacity.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: Please see the
attachment for this response. Transmission substations do not serve load; they are
intended to move power between voltage levels on the grid. In the attachment is a list of
transformers connecting two different voltage levels and the power flowing through them.
The data is presented by the substation transformer. Because most of these transformers
are networked, the hourly load data should not be relied upon for analysis.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 18
REQUEST FOR PRODUCTION NO. 14: Please provide all of IPC’s marginal cost
studies completed in the last five years, and all associated workpapers in Excel
spreadsheet format. These can be, for example, a marginal cost study used in rate design
in a general rate case in Idaho, or a marginal cost of service study used for filings such
as the Oregon Resource Value of Solar (RVOS). In particular, please provide any recent
study (in the last five years) that calculates marginal capacity-related transmission and
distribution costs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: Two marginal cost
studies have been completed in the last five years. These were done for the years 2018
and 2021.
Attachments 1 – 10 contain the 2021 marginal cost study and associated
workpapers. The marginal cost of energy was determined from the simulated hourly
operation of the Company’s power supply system over 67 streamflow conditions for the
five years 2021 through 2025. A 2021 test year net power supply run was used for the
base marginal cost run, and then updated loads and resource considerations were
applied for 2022 - 2025. Idaho Power quantified base case net power supply expenses
for each year, and the model was run a second time (per year) with fifty megawatts of
load added across all hours. The difference in monthly power supply expenses between
the base run and the base-plus-50-megawatt run was averaged over the five years. It
was divided by the difference in monthly megawatt hours to produce an average monthly
marginal cost per megawatt hour.
The 2021 marginal cost of transmission reflects the planned investment included
in the capital budget and forecasts for 2021 through 2030 at the time of the study. The
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 19
investment is driven by peak load growth on the system. Therefore, that portion of
marginal transmission costs is assigned to the months based on relative monthly peak
load growth from 2021 through 2030. The two quantities are summed by month. This
method results in the assignment of marginal transmission capacity costs to each of the
twelve months of the year.
Attachments 11 – 20 contain the 2018 marginal cost study and associated
workpapers. The marginal cost of energy was determined from the simulated hourly
operation of the Company’s power supply system over 89 streamflow conditions for 2019
through 2023. A 2019 test year net power supply run was used for the base marginal cost
run, and then updated loads and resource considerations were applied for 2020 - 2023.
Idaho Power quantified base case net power supply expenses for each year, and the
model was run a second time (per year) with fifty megawatts of load added across all
hours. The difference in monthly power supply expenses between the base run and the
base-plus-50-megawatt run was averaged over the five years. It was divided by the
difference in monthly megawatt hours to produce an average monthly marginal cost per
megawatt hour.
The 2018 marginal cost of transmission reflects the planned investment included
in the capital budget and forecasts for 2019 through 2028 at the time of the study. The
investment is driven by peak load growth on the system. Therefore, that portion of
marginal transmission costs is assigned to the months based on relative monthly peak
load growth from 2019 through 2028. The two quantities are summed by month. This
method results in the assignment of marginal transmission capacity costs to each of the
twelve months of the year.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 20
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 21
REQUEST FOR PRODUCTION NO. 15: Please provide information on the IPC’s
currently approved capital cost structure used to set rates in Idaho, including return on
debt, return on equity, return on preferred stock, percentages for each, and IPC’s
weighted average cost of capital.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: The Company’s
authorized overall Idaho rate of return in the Company’s last general rate case (“GRC”),
per Order No. 32426, is 7.86 percent. A capital structure was not specified in the Order.
The response to this Request is sponsored by Mark Annis, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 22
REQUEST FOR PRODUCTION NO. 16: Please provide, if available, any Real
Economic Carrying Cost (RECC) factors used by IPC, as well as the workpapers used to
derive them.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Idaho Power does not
use any Real Economic Carrying Cost factors.
The response to this Request is sponsored by Tami White, Budget and Revenue
Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 23
REQUEST FOR PRODUCTION NO. 17: Please provide the following load data:
a. Please provide in Excel spreadsheet format the monthly retail peak demands
(in MW) for the most recent calendar year for which data is available, (i) for all
IPC customers and (ii) broken down by customer class, as well as the date and
time on which each of those Idaho system and class peaks occurred.
b. Please provide in Excel spreadsheet format representative hourly load profiles
(8,760 hourly loads in a year) for the following IPC customer classes: (1)
residential, (2) small commercial or small general service, and (3) large
commercial / large general service / industrial customers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17:
a. Please see the attachment for the monthly retail peak demands for all Idaho
Power customers. Idaho Power’s established process is broken out by rate, not
class; therefore, the values within the attachment are from load research
sampling estimates of peak demand by rate. Special Contracts include
individual customer data and were therefore excluded from the data provided.
b. Please see the attachment for the load shape of average customers without
impact of demand response programs. Idaho Power’s established process is
broken out by rate, not class; therefore, these values are from load research
sampling estimates by rate.
The response to this Request is sponsored by Jordan Prassinos, Load Research
and Forecasting Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 24
REQUEST FOR PRODUCTION NO. 18: Please provide the IPC’s most recent
cost-effectiveness analyses of its demand-side resources, including energy efficiency
(EE) and demand response (DR) programs that it has submitted to the Idaho Public
Service Commission. Please include all workpapers for these cost-effectiveness
analyses, including the alternate or avoided costs that IPC used, in Excel spreadsheet
format.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: Please see the
attachment provided for this response. This attachment is the same that was filed in
response to the Commission Staff’s Request No. 1 in Case No. IPC-E-22-08.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 25
REQUEST FOR PRODUCTION NO. 19: Please provide:
a. The IPC’s current system average line loss factors, for both its transmission
and distribution systems, which it uses to set rates. Please provide these line
loss factors by voltage level if you have that level of disaggregation.
b. Please also provide the source documents or line loss study used to produce
these factors.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: Please see the following
responses regarding line losses:
a. Line loss factors at the time of the Company’s most recent GRC, Case No. IPC-
E-11-08, were used in the process to develop customer rates. The most recent
line loss study at the time of the last GRC was prepared in 2003. Allocation
factors which assign transmission and distribution plant in the process of
developing customer rates are based on generation-level (customer load
grossed up to account for line losses) system coincident demand for
transmission, or non-coincident demand for distribution plant. 2011 GRC loss
factors are as follows at the respective service levels:
Service Level Volta e pplicable Rate Schedule
Loss
Facto
Transmission 45 kV or higher 30 (DOE); 09T; 19T 5.5%
Distribution Stations 12.5 kV to 34.5 kV 26 (Micron); 29 (Simplot) 6.5%
Distribution Primary 12.5 kV to 34.5 kV 09P; 19P 10%
Distribution
Secondary
480 volts or less Residential; 07; 09S; 15;
19S; 24S; 40; 41; 42
13%

b. Please see the attachment provided for this request.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 26
REQUEST FOR PRODUCTION NO. 20: Please provide the following data on any
purchases or sales of Renewable Energy Credits (RECs) that IPC has made in the 5
years 2017-2021 plus 2022 to date:
a. Volume of RECs (MWh) bought and sold, by month
b. Average purchase and sales prices, by month
c. Any study, report, or forecast that IPC has conducted or used to understand
the market for RECs in the WECC.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Please see the following
responses regarding REC purchase and sales:
a. The data is provided in the attachment. The first worksheet, Idaho Power-
owned RECs, details the sales of Idaho Power-owned RECs in Column B and
the average sales price in Column C. The second worksheet, Green Power
Program RECs, details the Green Power Program REC sales to customers and
Idaho Power’s REC purchases from a third-party vendor to fulfill those sales.
These two functions’ sales are recorded differently. For Idaho Power-owned
RECs, sales are recorded when the REC is transferred to the buyer. Sales for
the Green Power Program are recorded when participants’ payments are
received.
b. Please see the response to Request No. 20a.
c. The REC market is very fragmented and illiquid, so Idaho Power uses multiple
sources to form a view of current REC market prices:
1. Review daily reports from multiple REC brokers, which detail all current
market REC asking prices and bids;
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 27
2. Consistently engage with renewable market participants (i.e., brokers,
buyers and sellers, developers) to gauge the REC market fundamentals,
such as regulatory updates, supply and demand changes;
3. Participate in REC market conferences and meetings to stay informed on
current REC market trends and the impact on prices of our REC products.
The response to this Request is sponsored by Mike Marshall, Regulatory
Compliance & Risk Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 28
REQUEST FOR PRODUCTION NO. 21: Please provide IPC’s most recent filing
at the Oregon Public Utilities Commission of its Resource Value of Solar (RVOS), as
directed in Oregon PUC Order No. 19-022 in Docket UM 1911 and any subsequent
orders. Please provide all workpapers for the calculations in this RVOS filing.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: The most recent RVOS
filing was made December 11, 2020, with the OPUC and is available in Docket UM 1911.2
Please see the four attachments for the related workpapers.
The response to this Request is sponsored by Mark Annis, Regulatory Consultant,
Idaho Power Company.

DATED at Boise, Idaho, this 2nd day of September 2022.

LISA D. NORDSTROM
Attorney for Idaho Power Company

2 https://edocs.puc.state.or.us/efdocs/HAD/um1911had16121.pdf

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 29
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 2nd day of September 2022, I served a true and
correct copy of Idaho Power Company’s Response to the First Production Request of the
Idaho Conservation League to Idaho Power Company upon the following named parties
by the method indicated below, and addressed to the following:

Commission Staff
Riley Newton
Chris Burdin
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

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IdaHydro
C. Tom Arkoosh
Amber Dresslar
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

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Idaho Conservation League
Marie Kellner
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702

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Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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Lance Kaufman, Ph.D.
4801 W. Yale Ave.
Denver, CO 80219

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X Email lance bardwellconsultin .com

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 30
City of Boise
Mary Grant
Deputy City Attorney
Boise City Attorney’s Office
150 North Capitol Boulevard
P.O. Box 500
Boise, Idaho 83701-0500
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Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
PO Box 500
Boise, Idaho 83701-0500

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Industrial Customers of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707

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Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY - 31

Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, Idaho 83703
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Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho
3778 Plantation River Dr., Suite 102
Boise, ID 83703

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Richard E. Kluckhohn, pro se
Wesley A. Kluckhohn, pro se
2564 W. Parkstone Dr.
Meridian, ID 83646
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Idaho Solar Owners Network
Joshua Hill
1625 S. Latah
Boise, ID 83705
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ABC Power Company, LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, ID 83646
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Stacy Gust, Regulatory Administrative
Assistant