20230306IPC to Staff 1-25.pdf

Donovan E. Walker
Lead Counsel
[e-mail]

March 6, 2023

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-23-01
In the Matter of Idaho Power Company’s Application for a Certificate of
Public Convenience and Necessity for the Boardman to Hemingway 500-
kV Transmission Line

Dear Ms. Noriyuki:

Enclosed for electronic filing, please find Idaho Power Company’s Response to the
First Production Request of Commission Staff. 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.

Idaho Power Company values an open discovery process and takes seriously its
role in maintaining the security of the electric system that services its customers. In light
of recent regional and national infrastructure attacks, the Commission may wish to re-
evaluate unfettered access to infrastructure information by parties who sign the
Commission’s Protective Agreement. Because certain attachments contain confidential
information and critical energy infrastructure information (CEII), the FTP site is divided
between CEII, 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, and the CEII information will be
provided to Staff only unless the Commission or its legal counsel directs otherwise.

RECEIVED
2023 March 6, PM 5:03
IDAHO PUBLIC
UTILITIES COMMISSION
Jan Noriyuki
March 6, 2023
Page 2

If you have any questions about the attached filing, please do not hesitate to contact me.

Very truly yours,

Donovan E. Walker
DEW:sg
Enclosures

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-23-01
Idaho Power Company’s Application for a Certificate of Public Convenience and
Necessity for the Boardman to the Hemingway 500-kV Transmission Line

The undersigned attorney, in accordance with RP 67, believes that Idaho Power
Company’s Response to Staff’s Request for Production No. 25, included with Idaho
Power Company’s Response to Staff’s First Production Request dated March 6, 2023,
contains information that constitutes critical energy infrastructure information under
section 215A of the Federal Power Act, is confidential as described in Idaho Code § 74-
101, et seq. (e.g., § 74-105(4)(b)), and § 48-801, et seq., and as such is exempt from
public inspection, examination, or copying.

DATED this 6th day of March 2023.

Donovan Walker
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY FOR
THE BOARDMAN TO HEMINGWAY 500-KV
TRANSMISSION LINE.
)
)
)
)
)
)
)

CASE NO. IPC-E-23-01

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“IPUC or
Commission”) dated February 13, 2023, herewith submits the following information:

RECEIVED
2023 March 6, PM 5:03
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 1: Please provide supporting documents
and workpapers with formulas intact for all Company testimony and exhibits.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the
Company’s Response to Request for Production No. 3 for a revised version of
Confidential Exhibit No. 11 in electronic format with formulas intact. In addition,
Attachment 1 to the Company’s Response to Request for Production No. 19 includes an
updated Exhibit No. 9. All other supporting documents and workpapers have been
provided.
The response to this Request is sponsored by Donovan Walker, Lead Counsel,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 2: Please provide detailed and legible
project maps portraying the operational components (substations, lines, etc.) and
proposed transfer components, as described in agreements between the Company and
its partners. Indicate name, physical location, agreement reference(s), and ownership.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see Figure 1
below for a map of the B2H project showing the surrounding northwest 500-kilovolt
(“kV”) system and Idaho Power transmission system. Figure 2 is a map of the Goshen
area assets, and Figures 3 and 4 include a map of the Four Corners assets and the
Four Corners asset path. In addition, the table below lists the components described in
agreements between the Company and its partners, along with physical locations,
agreement reference(s), and ownership.
Component(s) Physical
Location
Agreement Reference(s)
with Agreement
Numbers from Ellsworth
Testimony
Existing
Ownership
Proposed
Ownership
B2H Project (Longhorn
to Hemingway 500-kV)
Eastern
Oregon and
Southwest
Idaho
(Figure 1)
1) Joint Permit Funding
Agreement
2) NITSA – Goshen
Load
3) NITSA – Idaho Falls
Load
4) Purchase, Sale, and
Security Agreement
6) Amended JOOA
7) Construction Funding
Agreement
8) Longhorn Substation
Funding Agreement

N/A Idaho Power:
45.45%
PacifiCorp:
54.55%

B2H Midline Series
Cap Station
Near North
Powder 230-kV
Station
(Figure 1)
6) Amended JOOA
7) Construction Funding
Agreement

N/A Idaho Power:
45.45%
PacifiCorp:
54.55%

B2H Integration 230-kV
Projects: Hemingway –
Bowmont #2,
Bowmont-Hubbard
Treasure
Valley
(Figure 1)
N/A N/A Idaho Power
100%

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
Midpoint 500/345-kV
Transformer Upgrade
(2nd Transformer)
Midpoint
Substation
(Figure 1)
6) Amended JOOA
9) Midpoint Transformer
Construction Agreement

N/A Jointly owned
Idaho Power and
PacifiCorp
Idaho Midpoint West
Assets:
Midpoint 500/345-kV
Transformer
Midpoint – Hemingway
500-kV
Midpoint
Substation and
Southern Idaho
(Figure 1)
5) JPSA
6) Amended JOOA
Jointly
Owned
PacifiCorp
and Idaho
Power
Jointly owned
Idaho Power and
PacifiCorp,
PacifiCorp gains
600 MW East to
West ownership
on Midpoint West
Kinport – Midpoint
345-kV Series Cap
Bank
Kinport
Substation
(Figure 1)
6) Amended JOOA
10) Kinport Capacitor
Bank Construction
Agreement

N/A Jointly owned,
Idaho Power and
PacifiCorp
Idaho Borah West
Assets:
Kinport-Midpoint 345-
kV
Borah-Adelaide-
Midpoint 345-kV
Borah-Adelaide 345-kV
Adelaide-Midpoint 345-
kV

Southern Idaho
(Figure 1)
5) JPSA
6) Amended JOOA
Jointly
owned
Jointly owned,
PacifiCorp gains
600 MW East to
West and 300 MW
West to East
Goshen Area Load
Serving Assets
Eastern Idaho
(Figure 2 –
highlighted in
green, load
points of
delivery in
yellow)
2) NITSA for Goshen
Load
3) NITSA for Idaho Falls
Load
5) JPSA
6) Amended JOOA
PacifiCorp Jointly owned,
Idaho Power
gains capacity to
serve BPA SE
Idaho load
customers.
Four Corners Assets E. Idaho, Utah,
SW Colorado,
NW New
Mexico
(Figures 3 & 4)
5) JPSA
6) Amended JOOA
PacifiCorp Jointly owned,
Idaho Power
gains 200 MW
bidirectional
capacity
Idaho Power 500 MW
Mid-C to Longhorn
PTP Reservation on
BPA Transmission
Central
Washington
(Vantage) to
Longhorn
(Figure 1)
N/A N/A N/A

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5

Figure 1. Map of the B2H Project, B2H Midline Cap Station, B2H 230-kV Integration Projects,
Midpoint 500/345-kV Transformer Upgrade, and the Kinport – Midpoint 345-kV Series
Capacitor. Note, map is illustrative and not to scale.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 6

Figure 2. Goshen Area Assets

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7

Figure 3. Four Corners Assets

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
Figure 4. Four Corners Asset Path

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
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 3: The Company's Exhibit 11 provides a
high-level overview of the Boardman to Hemingway ("B2H") cost estimate. Please
provide the underlying worksheets showing the major expense components for the
following line items in the exhibit:
a. Transmission Line Construction and Mitigation Direct Costs,
b. Pre-Construction Costs,
c. Right of Way Option Costs,
d. Substation Total,
e. Local Interconnection Costs, and
f. Idaho Power AFUDC & Property Tax.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: See Confidential
Attachment 1. Please note, subsequent to filing the Company’s request in this case,
Idaho Power identified two errors in Confidential Exhibit No. 11. First, the Company
found an error in the calculation of the Idaho Power share of Total B2H Project
Estimated Costs. In addition, the Company identified additional Idaho Power-specific
costs that were inadvertently excluded from the B2H project cost estimate. Therefore,
Confidential Attachment 1 includes the revised December 2022 cost estimate in column
(F) reflecting the two adjustments (see lines 37 and 49) on the first tab and the above
detailed estimate of B2H project costs on the second tab.
The response to this Request is sponsored by John Wonderlich, Finance Team
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 4: Company Witness Barretto testifies that
"[t]he B2H project will require...removal of 12 miles of existing 69-kV transmission line,
rebuilding 0.9 miles of a 230-kV transmission line, and rebuilding of 1.1 miles of an
existing 138-kV transmission line into a new right-of-way." Barretto Direct at 3. Please
provide the following:
a. A detailed explanation of the need,
b. The location,
c. The scope of work, and
d. The estimated cost.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: The 138-kV and 230-kV
lines rebuilds are the result of constraints in existing right-of-way areas and provide a
cost-effective option for siting B2H with minor lower voltage transmission line
modifications to assume such right-of-way.
138-kV rebuild. This rebuild is located near Farewell Bend and I-84 and is the
result of extensive landowner consultation, micrositing, and detailed analysis of the
corridor during the siting phase of the B2H project. In order to accommodate a more
economical right-of-way for B2H, and allow for the wider constrained 500-kV right-of-
way, the 138-kV line can be moved further away from the freeway. The scope of the
work includes the removal of approximately 1.1 miles of the Ontario-Huntington 138-kV
line and replacement with steel self-supporting H-frame structures. The design is
currently underway and being performed by HDR, Inc. The map below illustrates the
138-kV rebuild location along the B2H route. The current cost estimate, excluding
contingency, overheads, Allowance for Funds Used During Construction (“AFUDC”),

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
and taxes is approximately $275,000.

230-kV rebuild. Similar to the 138-kV rebuild, the 230-kV rebuild is the result of
landowner consultation as well as topography constraints. As the line crosses Highway
86, there is a small canyon that accommodates both the 500-kV line and 230-kV line but
requires the 230-kV line to be moved to the west to allow for both lines in the canyon. In
addition, as a result of the National Historic Oregon Trail Interpretive Center (“NHOTIC”)
visual mitigation requirements, Idaho Power assumes a portion of the 230-kV right-of-
way for B2H as it minimizes impacts to the agricultural field, the visuals at NHOTIC, and
sage-grouse habitat. This portion of B2H will immediately transition to H-frames and will
closely follow the topography and edge of an agricultural field.
The scope will be to remove and replace approximately 0.9 miles of the Quartz-
North Powder/LaGrande 230-kV line with steel self-supporting H-frame structures. The
design is currently underway and being performed by HDR, Inc. The map below
illustrates the 230-kV rebuild location along the B2H route. The current cost estimate,
excluding contingency, overheads, AFUDC, and taxes is approximately $315,000.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12

69-kV removal. The B2H project will assume the existing right-of-way for a 69-
kV transmission line along Bombing Range Road on property that is owned by the US
Navy. Currently, the line feeds the Bonneville Power Administration’s (“BPA”) Ione
substation however BPA plans to take service off of Umatilla Electric Cooperative’s
(“UEC”) 230-kV system and build a new 230/69-kV substation, currently identified as the
Strawberry Fields Substation. This substation is currently being permitted and designed
by BPA and is scheduled to be in-service by the spring of 2025. With assumption of the
existing right-of-way for siting of the B2H project, the removal of the 69-kV line is
necessary. As such, the cost associated with the removal is embedded in the total B2H
project costs and not currently broken down at that particular level of detail.
This area is heavily constrained by height restrictions due to the US Navy’s aerial
bombing range field directly to the west of Bombing Range Road. Idaho Power worked
extensively with BPA and the US Navy to develop this plan as a solution to siting B2H.
The response to this Request is sponsored by Joe Stippel, Principal Engineering
and Construction Project Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
REQUEST FOR PRODUCTION NO. 5: Company Witness Ellsworth discusses
both the "Midline Series Capacitor substation" associated with the B2H Project Joint
Construction Funding Agreement, and the "Kinport - Midpoint 345-kV Series Capacitor
Bank Project" associated with the Kinport Capacitor Bank Construction Agreement.
Ellsworth Direct at 23-24. To help Staff distinguish between these two projects, please
provide the following for each project:
a. The project purpose,
b. The project location,
c. The project scope of work, and
d. The estimated project cost.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: The Midline Series
Capacitor Substation is a 500-kV capacitor bank substation to be added near the
midline point on the B2H 500-kV line. The Company is anticipating the substation will
be located near the Company’s North Powder Switching Station in Eastern Oregon. The
substation is necessary to add a third series capacitor bank on the line to reduce
simultaneous interactions between the Northwest AC Southern Intertie 500-kV lines
across Oregon, central and southern Oregon load, and Path 14 (Idaho to Northwest).
The project was identified through a Joint Study performed by BPA, PacifiCorp, and
Idaho Power from summer 2020 through early 2021. The estimated cost of the Midline
Series Capacitor Substation is of which Idaho Power will be responsible for
45.45 percent.
The Kinport – Midpoint 345-kV Series Capacitor Bank project is a new 345-kV
series capacitor bank to be added to the Kinport – Midpoint 345-kV line. The series

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
capacitor bank will be installed within the existing Kinport Substation near Pocatello,
Idaho. The project is needed as a system upgrade to increase the total Borah West
path capability to facilitate the 600 MW east-to-west transmission asset exchange to
PacifiCorp from Idaho Power. The estimated project cost is .
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
COMMISSION STAFF - 15
REQUEST FOR PRODUCTION NO. 6: The Company's Application describes a
complex plan with many significant projects and transactions that are distinct from
constructing the B2H transmission line. Staff offers the following list of projects and
transactions it has noted in the Application:
a. Buyout Bonneville Power Association's ("BPA") Permit Interest.
1. Establish the Joint Permit Funding Agreement.
2. Establish the Purchase, Sale, and Security Agreement.
3. Establish the Network Integration Transmission Service Agreement
("NITSA") for Goshen load.
4. Establish the NITSA for Idaho Falls load.
5. Establish a point-to-point ("PTP") Transmission Service Agreement ("TSA")
from the Mid-Columbia ("Mid-C") hub to the proposed Longhorn substation.
6. BPA will redirect two 100 MW PTP TSAs from the Company to PacifiCorp.
7. Establish the Longhorn Substation Funding Agreement.
b. Construct the B2H Core Project.
1. Establish the Joint Construction Funding Agreement with PacifiCorp.
2. Construct the main transmission line.
3. Rebuild or remove certain other transmission segments.
4. Construct the Longhorn substation.
5. Upgrade the Hemingway substation.
6. Construct the Midline Series Capacitor substation.
c. Asset Swaps and Construction Agreements with PacifiCorp.
1. Company transfer to PacifiCorp transmission assets between Midpoint and

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
Borah for 300 MW west-to-east capacity.
2. Company transfer to PacifiCorp transmission assets between Borah and
Hemingway for 600 MW east-to-west capacity.
3. PacifiCorp transfer to the Company transmission assets between Populus
and Four Corners for 200 MW of bi-directional capacity.
4. PacifiCorp transfer to the Company identified Goshen area assets.
5. Establish a construction agreement and construct the Midpoint 500/345-kV
Transformer Project.
6. Establish a construction agreement and construct the Kinport-Midpoint 345-
kV Series Capacitor Bank Project.
For each of these projects or transactions above (and any others inadvertently omitted
by Staff), please provide the following:
a. Please identify which of these projects/transactions that the Company is seeking
Commission authorization under the Certificate of Public Convenience and
Necessity ("CPCN").
b. Please identify which of these projects/transactions that the Company is seeking
Commission authorization in this case but not specifically under the CPCN.
c. Please identify which of these projects/transactions that the Company plans to
seek Commission authorization outside of this case. If seeking authorization
outside of this case, when and how will the Company be seeking authorization?
d. For any projects/transactions that will be authorized outside of this case, please
discuss possible dependencies between them and the included
projects/transactions.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
a. The Company is seeking a Commission order granting a CPCN for the B2H
project. The B2H project consists of the following above identified items for which
a CPCN, if approved, would encompass:
b. Construct the B2H Core Project.
2. Construct the main transmission line.
3. Rebuild or remove certain other transmission segments.
4. Construct the Longhorn substation.
5. Upgrade the Hemingway substation.
6. Construct the Midline Series Capacitor substation.
Please note, while not all the items identified above are a component of the
Company’s request in this case, each one is critical for defining the B2H project
ownership and future operations.
b. In support of Idaho Power’s request for a CPCN related to the B2H project as
discussed in part (a), the Company is seeking the Commission’s review of the
relevant partnership agreements under the Term Sheet. Idaho Power believes
that by granting the requested CPCN in this case, the Commission would
necessarily be indicating that the underlying partnership agreements that provide
for the line to be constructed are reasonable in their current states. While the
Company is not seeking explicit approval of the partnership agreements in this
case, the agreements form the foundational information necessary to derive the
estimated cost of the project Idaho Power will ultimately seek to recover from its
customers.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
c. All of the items identified in section c. Asset Swaps and Construction Agreements
with PacifiCorp are components of the proposed asset exchange between Idaho
Power and PacifiCorp that will facilitate the objectives of the two parties as
envisioned in the various B2H agreements. The asset exchange will not be
effective until energization of the B2H project which is expected to occur in 2026.
Both the Company and PacifiCorp will request approval of the agreement
pursuant to Idaho Code § 61-328, detailing the benefits associated with the
assets being exchanged and demonstrating the transaction is consistent with the
public interest, in a future proceeding at a time that would allow for a Commission
determination prior to energization of B2H.
d. The asset exchanges facilitate the ownership and operation agreements
necessary for B2H by allowing for: (1) the transfer to PacifiCorp by Idaho Power
of transmission assets between Midpoint and Borah to facilitate 300 MW of west-
to-east capacity, (2) the transfer to PacifiCorp by Idaho Power of transmission
assets between Borah and Hemingway to enable an additional 600 MW of east-
to-west capacity, increasing from the current 1,090 MW to 1,690 MW, (3) the
transfer to Idaho Power by PacifiCorp of transmission assets between Populus,
Mona, and Four Corners to allow for 200 MW of bi-directional capacity, and (4)
the transfer by PacifiCorp to Idaho Power of an ownership interest in identified
Goshen area assets. Therefore the B2H project and the asset exchanges are
interdependent.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution, and Resource Planning Director, Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19
REQUEST FOR PRODUCTION NO. 7: Company Witness Ellsworth testifies
that "...the Parties' capacity needs, strategies, and goals associated with the B2H
project have evolved... BPA will transition out of its role as a joint permit funding
coparticipant..." Ellsworth Direct at 10. Please explain why BPA wants out of its role.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: Please see
Attachments 1 and 2 for two letters prepared by BPA to stakeholders and customers in
the region explaining their reasoning and decision-making process for transitioning out
of their role as a joint permit funding coparticipant.
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
COMMISSION STAFF - 20
REQUEST FOR PRODUCTION NO. 8: Please provide the Company's 20-year
Load & Resource Balance ("L&RB") showing the year and deficits justifying the need for
B2H. Also, please provide the following:
a. A list of any new resource projects (including their rated capacity) supplying the
Company that have, or will, come online between the time the L&RB was
established and before B2H is energized.
b. If any of these projects are reflected in the L&RB, please correlate them.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Please see Attachment
1 for the L&R balance used for modeling of the 2021 IRP.
a. There are a few new resource projects that are now scheduled to come online
since the creation of the L&R balance used for the 2021 IRP. They are as
follows:
 2023:
i. Black Mesa Solar Power Purchase Agreement (“PPA”) (40 MW) +
Battery Storage (40 MW)
ii. Hemingway Battery Storage (80 MW)
iii. Grid-distributed Batteries (11 MW)
 2024:
o Franklin Solar PPA (100 MW) + Battery Storage (60 MW)
o Additional Hemingway Battery Storage (12 MW)
 2025:
o Pleasant Valley Solar PPA (200 MW)
o Additional 2025 RFP resources are currently in a final shortlist

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 21
analysis
b. None of these projects are reflected in the L&R balance.
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
COMMISSION STAFF - 22
REQUEST FOR PRODUCTION NO. 9: Please explain how the Company will
serve native load customers if B2H is not approved?
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Comparing the results
of the 2021 IRP between the preferred portfolio and the next lower cost non-B2H
portfolio, shown on pages 66 and 68 of the 2021 Integrated Resource Plan Appendix C:
Technical Report, will demonstrate how Idaho Power will serve native load customers if
B2H is not in service. The resource differences are:
1. Delayed exits from coal operations of Jim Bridger Units 3 and 4 from 2025
and 2028 to 2034,
2. Construction of two segments of the Gateway West transmission project in
2027 and 2033,
3. 500 MW of additional wind resources built between 2024 and 2030,
4. 500 MW of additional solar resources built between 2025 and 2037,
5. Nearly 500 MW of additional storage resources built between 2025 and 2035,
and
6. A 60 MW reduction of additional demand response between 2025 and 2039.
These portfolio changes necessitated by the removal of B2H resulted in an additional
portfolio cost of $265.5 million based on the 2021 IRP analysis. It should also be noted
that, due to the passage of time between the preparation of the 2021 IRP and today,
certain components of the above-referenced resource portfolio may not be feasible in
the near-term de to procurement and/or construction lead-times.
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
COMMISSION STAFF - 23
REQUEST FOR PRODUCTION NO. 10: Please explain how the Company will
serve native load customers if B2H is approved but completion is delayed beyond the
2026 deficiency date?
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Comparing the results
of the 2021 IRP between the preferred portfolio and Base with B2H in 2027 portfolio, will
demonstrate how Idaho Power will serve native load customers if B2H is delayed one
year. The one-year delay in B2H’s on-line date kicks off a cascading series of
differences in the next least cost portfolio. Those differences prior to 2027 include the
procurement of an additional 200 MW of wind, 200 MW of solar, and 200 MW of
storage. In addition to the resource procurements, the delay in B2H timing also delays
an exit from coal operations of Jim Bridger Unit 3 by one year. After the delayed B2H
line is in-service, the change in resources procured because of its delay cause changes
to the rest of the plan. Based on the 2021 IRP modeling, the resource changes
discussed result in a portfolio cost increase of $69 million.
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
COMMISSION STAFF - 24
REQUEST FOR PRODUCTION NO. 11: Please explain all potential funding
sources the Company has considered and pursued to finance building B2H by
answering the following:
a. Has the Company pursued available Federal funds for grid resilience and
transmission? If not, why not? If yes, please describe the funds available, status
of funding pursued, and how these funds potentially reduce impact to
ratepayers?
b. Has the Company pursued available State funds through the Office of Energy
and Mineral Resources ("OEMR")? If not, why not? If yes, please describe the
funds available, status of funding pursued, and how these funds potentially
reduce impact to ratepayers?
c. Has the Company pursued funds through the Federal Emergency Management
Agency ("FEMA") and the Office of Emergency Management("OEM")? If not, why
not? If yes, please describe the funds available, status of funding pursued, and
how these funds potentially reduce impact to ratepayers?
d. Has the Company applied for any grants or other funding for the project? If so,
what were the sources, amounts, and application dates?
e. Has the Company been awarded any grants or other funding for the project? If
so, what were the sources, amounts, and dates awarded?
RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
a. Idaho Power has hired consultants that are experts in Federal Grants for grid
resilience and transmission. The Company’s interactions with the Department of
Energy (“DOE”), that have been confirmed by advisement by Idaho Power’s

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 25
consultants, identified that projects such as B2H that have been significantly
permitted, engineered, and have had substantial funds expended are generally
not candidate projects for Infrastructure Investment and Jobs Act (“IIJA”)
programs based on the IIJA guidelines for qualifying projects. While B2H is not
an ideal candidate project, future high voltage transmission projects are an area
that the Company will continue to monitor for grant opportunities. Additionally,
outside of the B2H project, Idaho Power submitted two concept papers to the
DOE for the Grid Resilience and Innovation Partnership Program (GRIP) in
December 2022 as a prerequisite for submitting full applications. In February
2023, the DOE notified Idaho Power that the concept papers aligned well to the
IIJA guidelines and encouraged the Company to submit full applications for both
projects. Idaho Power is currently in the process of preparing the applications.
b. For the reasons stated above, Idaho Power has not identified any applicable to
B2H available state funds through the OEMR. However, the Company is actively
working with OEMR for state funded grants for Grid Resiliency projects outside of
B2H.
c. For the reasons stated above, Idaho Power has not identified any applicable
funding opportunities for the B2H project through FEMA and the OEM to date.
d. Idaho Power has not applied for grants or other funding for the B2H project.
e. Idaho Power has not been awarded any grants or other funding for the B2H
project.
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
COMMISSION STAFF - 26
REQUEST FOR PRODUCTION NO. 12: For BPA's construction of the Longhorn
substation, please explain when environmental compliance laws are expected to be
met? Ellsworth Direct at 50.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: It is the Company’s
understanding that BPA is targeting a 2024 or 2025 in-service date for Longhorn
substation, in advance of the need for B2H to connect in 2026. The Company is not
aware of the particulars related to environmental permitting associated with Longhorn.
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
COMMISSION STAFF - 27
REQUEST FOR PRODUCTION NO. 13: Please describe the Company's
contingency plans if BPA decides not to pursue construction of the Longhorn substation.
B2H Term Sheet Item No. 7 at 26.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: It is the Company’s
understanding that BPA is planning to break ground on the initial phase of the Longhorn
substation during the first half of 2023. BPA is planning to build the substation prior to
the interconnection of B2H to provide service to another customer. In the unlikely event
that BPA decides not to pursue construction of the Longhorn substation, the Company
will look to find a new 500-kV interconnection point for B2H in the area.
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
COMMISSION STAFF - 28

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 29

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 30

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 31

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 32

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 33
REQUEST FOR PRODUCTION NO. 15: Please describe all lawsuits in process
for the B2H project. In the response, please include the following:
a. Case No.,
b. County filed in,
c. Name of parties,
d. Case caption,
e. Date filed, and
f. Any other relevant information.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
The following is a list of the known pending lawsuits and regulatory proceedings
regarding the B2H Project:

Venue Case No(s).Petitioners/Applicant/
Plaintiff Defendant(s)/Intervenor(s) Date Filed Nature of Case and Status of Litigation
Idaho Public 
Utilities 
Commission
IPC‐E‐23‐01 Idaho Power Company Idaho Irrigation Pumpers 
Association, Inc., Idaho 
Industrial Customers of Idaho 
Power, city of Boise City, 
Micron Technology, Inc., and 
Idaho Conservation League
1/10/2023 Idaho Power applied for a Certificate of 
Public Convenience and Necessity before 
the Idaho Public Utilities Commission. At 
this time, no schedule has been set.
Oregon Supreme 
Court
S069919, S069920, 
and S069924
Stop B2H Coalition, 
Michael McAllister, and 
Irene Gilbert
Oregon Department of 
Energy, Oregon Energy 
Facility Siting Council, and 
Idaho Power Company
12/6/2022 Petitioners appealed EFSC’s final order, 
which approved a site certificate for the 
B2H Project. The appeals have been fully 
briefed and argued. The next step is for 
the Court to issue its decision, which the 
Court is required by statute to do by    
June 6, 2023.
Oregon Public 
Utility 
Commission
PCN 5 Idaho Power Company Stop B2H, Christopher Lyon, 
Kaye Foss, Meg Cooke, James 
Foss, Jason Gaskill, Susan 
Geer, Irene Gilbert, Joanne 
Rode, F. Steven Knudsen, 
Carol Fuji Kreider, Greg 
Larkin, Margie Lyon, Carl 
Morton, Julie Morton, Sam 
Myers, Skylan Myers, Timothy 
Proesch, John Williams, 
Wendy King, and PacifiCorp.
9/30/2022 Idaho Power applied for a Certificate of 
Public Convenience and Necessity before 
the Oregon Public Utility Commission. An 
evidentiary hearing is scheduled for April 
19‐20, and Idaho Power expects a final 
decision by June 30.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 34

The response to this Request is sponsored by David Stanish, Senior Counsel,
Idaho Power Company.

State of Oregon 
Circuit Court, 
Morrow County
21CV46147 Idaho Power Company Vanburen Family Property 12/1/2021 Right‐of‐entry case, whereby Idaho Power 
sought judicial confirmation of the 
Company's statutory right to enter the 
defendant's property to complete certain 
environmental and other surveys. In 
February 2022, the Circuity Court entered 
a General Judgment in Idaho Power's 
favor, providing the Company access to 
the property. In February 2023, Idaho 
Power moved to enforce the Company's 
right of access under the General 
Judgment. That motion is pending.
State of Oregon 
Circuit Court, 
Morrow County
23CV03300 Idaho Power Company Luciani, Beatrice, John 1/23/2023 Right‐of‐entry case, whereby Idaho Power 
is seeking judicial confirmation of the 
Company's statutory right to enter the 
defendant's property to complete certain 
environmental and other surveys.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 35
REQUEST FOR PRODUCTION NO. 16: Please describe all lawsuits resolved
for the B2H project. In the response, please include the following:
a. Case No.,
b. County filed in,
c. Name of parties,
d. Case caption,
e. Date filed,
f. Date resolved,
g. The outcome of the case, and
f. Any other relevant information.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16:
The following is a list of the resolved lawsuits regarding the B2H project:

Venue Case No. Plaintiff(s)Defendant(s)/Defendants‐
Intervenors Date Filed Nature of Case and Status of Litigation
United States 
District Court, 
District of Oregon
2:19‐cv‐1822‐SI Stop B2H Coalition, 
Greater Hells Canyon 
Council, Carol “Fuji” 
Kreider, Jim Kreider, and 
Gail Carbiener
U.S. Bureau of Land 
Management, U.S. Department 
of the Interior, Jose Linares, 
State Director, BLM 
Oregon/Washington, U.S. 
Forest Service, Tom Montoya, 
Forest Service Supervisor, 
Wallowa‐Whitman National 
Forest, Idaho Power Co. and 
PacifiCorp
11/12/2019 Stop B2H's federal court lawsuit challenging 
the BLM and Forest Service’s approval of 
rights‐of‐way for the B2H Project, including 
challenges related to National 
Environmental Policy Act (NEPA) 
compliance. On August 4, 2021, United 
States District Judge Michael Simon entered: 
(a) an Opinion and Order denying Plaintiffs’ 
motion for summary judgment and granting 
Defendants’ and Intervenor‐Defendants’ 
motions for summary judgment; and (b) a 
Judgment dismissing the case. No appeal 
was filed.
State of Oregon 
Circuit Court, 
Baker County
22CV02672 Idaho Power Company Bunch, Levi A 1/20/2022 Right‐of‐entry case, whereby Idaho Power 
sought judicial confirmation of the 
Company's statutory right to enter the 
defendant's property to complete certain 
environmental and other surveys. The 
parties settled, providing the Company 
access for the surveys, and the case was 
dismissed. ("Right‐of‐entry 
case/Settled/Dismissed")
State of Oregon 
Circuit Court, 
Union County
22CV02728 Idaho Power Company Free, Johnathan E & Diane L 1/20/2022 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Union County
21CV47304 Idaho Power Company Geer, Susan Et Al 12/10/2021 Right‐of‐entry case/Settled/Dismissed. 

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 36
State of Oregon 
Circuit Court, 
Umatilla County
21CV48563 Idaho Power Company Parcel 1‐Hemphill, Richard C & 
Jean E (Trs) Etal
12/22/2021 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Umatilla County
21CV48562 Idaho Power Company Parcel 2‐Hemphill, Richard C & 
Jean E (Trs) Etal
12/22/2021 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Umatilla County
21CV49034 Idaho Power Company Parcel 3 ‐Hemphill, Richard C & 
Jean E 
12/29/2021 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Malheur County
22CV05019 Idaho Power Company Jacobs, Jerry R. & Laura 2/8/2022 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Union County
21CV48510 Idaho Power Company Osburn, Danna Et Al 12/22/2021 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Morrow County
22CV02722 Idaho Power Company Sand Hollow Ranch, LLC 1/20/2022 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Baker County
22CV02793 Idaho Power Company Smoke Ranch LP 1/21/2022 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Umatilla County
22CV02694 Idaho Power Company White, Niel Owen 1/20/2022 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Morrow County
22CV02580 Idaho Power Company William J. Doherty Ranch, LLC 1/19/2022 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Morrow County
22CV02726 Idaho Power Company Ashbeck, Tony R & Gerald T 1/20/2022 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Malheur County
21CV48530 Idaho Power Company Lyon Family Living Trust 12/22/2021 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Morrow County
22CV02725 Idaho Power Company Myers, Jerry & Nancy 1/20/2022 Right‐of‐entry case/Settled/Dismissed. 
State of Oregon 
Circuit Court, 
Malheur County
21CV47320 Idaho Power Company Aston, Janet 12/10/2021 Right‐of‐entry case. The parties agreed to a 
Stipulated General Judgment, providing the 
Company access for surveys. ("Right‐of‐
entry case/Stipulated General Judgment")
State of Oregon 
Circuit Court, 
Union County
22CV02579 Idaho Power Company Dodson Family Trust 1/20/2022 Right‐of‐entry case/Stipulated General
State of Oregon 
Circuit Court, 
Umatilla County
21CV42341 Idaho Power Company Harvey, Cynthia Anne 11/1/2021 Right‐of‐entry case/Stipulated General
State of Oregon 
Circuit Court, 
Baker County
22CV02578 Idaho Power Company McCall, Leland R. 1/19/2022 Right‐of‐entry case. The parties entered a 
Stipulated Limited Judgment, providing the 
Company access for surveys and retaining 
jurisdiction by the Court. ("Right‐of‐entry 
case/Stipulated Limited Judgment")
State of Oregon 
Circuit Court, 
Union County
21CV47309 Idaho Power Company Collins, John & Connie 12/10/2021 Right‐of‐entry case. The Circuit Court Judge 
entered a Limited Judgment, providing the 
Company access for surveys and retaining 
jurisdiction with the Court. ("Right‐of‐entry 
case/Limited Judgment")
State of Oregon 
Circuit Court, 
Malheur County
21CV42267 Idaho Power Company White, David E                10/29/2021 Right‐of‐entry case/Limited Judgment
State of Oregon 
Circuit Court, 
Union County
21CV47303 Idaho Power Company Hall, Marlene L Et Al 12/10/2021 Right‐of‐entry case. The entered a General 
Judgment, providing the Company access for 
surveys. The defendant(s) did not appear in 
the case. ("Right‐of‐entry case/General 
Judgment via Default") 

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 37

The response to this Request is sponsored by David Stanish, Senior Counsel,
Idaho Power Company.
State of Oregon 
Circuit Court, 
Union County
21CV47301 Idaho Power Company Rice, Joel 12/10/2021 Right‐of‐entry case/General Judgment via 
Default
State of Oregon 
Circuit Court, 
Union County
22CV20394 Idaho Power Company Rice, Joel (2) 6/21/2022 Right‐of‐entry case/General Judgment via 
Default
State of Oregon 
Circuit Court, 
Union County
21CV47273 Idaho Power Company 516 Ranch Partnership etal 12/10/2021 Right‐of‐entry case. Idaho Power dismissed 
this case. 

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 38
REQUEST FOR PRODUCTION NO. 17: Please describe all known pending
lawsuits for the B2H project and include all known information about the pending
litigation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Please see the
Company’s Response to Request for Production No. 15.
The response to this Request is sponsored by David Stanish, Senior Counsel,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 39
REQUEST FOR PRODUCTION NO. 18: Company Witness Ellsworth testifies
that the Company assessed five different data points regarding Mid-C market
sufficiency. Ellsworth Direct at 78. To aid Staff's review of market sufficiency, please
provide the following:
a. The workpapers showing the Pacific Northwest forecast for 2030 winter and
summer peaks. Ellsworth Direct at 79.
b. The resource adequacy assessment performed by BPA. Ellsworth Direct at 79.
c. The workpapers evaluating the 6,389 MW of planned new resources through
2031. Ellsworth Direct at 80.
d. Please list the current firm power commitments the Company has with Mid-C
market sellers during the summer peak.
e. Please address the prospect of obtaining future Mid-C firm power commitments
for summer peaks in light of the new California, Oregon, and Washington policies
of electrification.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
a. Table 8 from the Idaho Power 2021 IRP Appendix D (2021 Appendix D_WEB
(idahopower.com) shows the 2030 winter and summer peak load estimates by
utility and season. The table was created from Edison Electric Institute load data
used for the Western Electricity Coordinating Council 2030 Anchor Data Set
Production Cost Model. Attachment 1 is the workbook with the forecasted load
data.
b. The Technical Appendix with the Capacity Analysis performed from the 2019 Pacific Northwest
Loads and Resources Study can be retrieved from the BPA website at the following link:
2019 WBK - Technical Appendix Volume 2 - Capacity Analysis (bpa.gov)

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 40
c. The 2021 Pacific Northwest Utilities Conference Committee Northwest Regional
Forecast included a list of potential new resources reported by northwest utilities
within their integrated resource plans to meet their own needs. The list from the
report that includes the 6,389 MW of new resources can be found in Table 18 of
Idaho Power’s 2021 IRP Appendix D (2021 Appendix D_WEB (idahopower.com).
d. Idaho Power purchases energy for the summer peak from a variety of
counterparties, and purchases for a given peak day may include purchases
arranged years in advance, purchases arranged months in advance, and
purchases arranged days in advance. The Company consistently monitors the
market and explores opportunities to secure supply for the peak season and
ensure a diversity of arrangements, counterparties, and term lengths for
purchases to serve load. Idaho Power currently has two firm energy purchases
arranged for the 2023 summer peak season: a 75 MW heavy load hour purchase
for July and August; and a 76 MW 16 hour a day, 7 day a week purchase for
June through September.
e. Please reference the fourth data point, starting on Page 79 of the Direct
Testimony of Mr. Ellsworth. Additional electrification is likely to impact winter
loads more than summer loads, considering movement away from natural gas
heating to electrical heating. The Pacific Northwest is already a winter peaking
area, and it is likely that additional electrification will only increase the gap
between summer and winter for that region. Electrification combined with state
Renewable Portfolio Standard (“RPS”) goals in California, Oregon, and
Washington will likely lead to the need to overbuild renewable resources to meet

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 41
the more challenging winter peak and continue to leave excess energy in the
summer months. For example, solar and solar plus storage resources are very
cost effective at meeting RPS targets and align very well with Idaho Power’s
summer peaking needs, but are much less effective at meeting winter needs, so
an overbuild of these resources in the Pacific Northwest may be necessary. The
Company looks to access summer energy needs from the market.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 42
REQUEST FOR PRODUCTION NO. 19: Please evaluate the likelihood that
pending permits will be issued in time to complete construction by the end of 2026. If
the delay risk is high for a permit, describe the potential impact and the Company's
plans to mitigate delays.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: Idaho Power believes
there is a high likelihood that the pending permits will be issued in time to complete
construction of B2H in 2026. Some permits are required only prior to construction of a
particular phase or segment of the B2H project and a limited or partial authorization to
construct in other areas may be obtained. Further, as evidenced by the updated Land
Use Approvals and Permits Required for the B2H Project chart included as Attachment
1, initially filed as Exhibit No. 9, the status of the permits and approvals is continually
changing as Idaho Power permits are issued and expected issuance dates are more
solidified.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 43
REQUEST FOR PRODUCTION NO. 20: Please provide Company guidelines for
affected landowner compensation related to the B2H project. If the Company does not
have guidelines, please explain why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: With regard to
compensation, Idaho Power has begun easement negotiations with landowners who
have project features on their property. Landowners will be compensated accordingly
for impacts for both permanent and temporary features. For each landowner whose
property the B2H project will cross, Idaho Power utilized licensed appraisers to prepare
an appraisal in accordance with the Uniform Standards of Professional Appraisal
Practice.

Attachments 1, 2, and 3 include the template agreements for which each option
agreement to purchase easements is based. Please note, the Access Road Easement
and Power Line Easement templates indicate access is granted or conveyed “for One
Dollar and other valuable consideration”. This is standard boiler plate language to
confirm that there was some consideration without revealing the actual amount paid to

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 44
the landowner. It does not mean Idaho Power is only offering compensation in the
amount of one dollar.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 45
REQUEST FOR PRODUCTION NO. 21: Please provide the following to explain
the Company's real estate acquisitions in relation to the B2H route:
a. How many real estate parcels ("segments") must the Company acquire access
and construction rights to construct B2H?
b. To date, how many segments has the Company acquired, and how many remain
to be acquired?
c. To date, how much has the Company spent to compensate landowners? How
much more does the Company expect to spend?
RESPONSE TO REQUEST FOR PRODUCTION NO. 21:
Idaho Power initially anticipated needing an easement on 422 parcels of land that
were expected to be physically impacted or traversed. However, the Company
has since determined that 37 of those parcels do not have project features and
therefore no access or easement option is required, for a total of 385 remaining
parcels.
b. To date, Idaho Power has option agreements for 65 parcels.
c. Idaho Power has been securing easement rights through option agreements,
which provide the Company the right to purchase an easement in the future at an
agreed-upon price in exchange for Idaho Power paying the landowner a sum of
money as an option fee. The Company has paid approximately in
option fees, and the total cost of the underlying easement rights (if Idaho Power
were to exercise its option rights) is approximately $. The Company
anticipates an additional $ in option fees and easement acquisition
costs associated with the B2H project easements. Idaho Power’s share of these

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 46
costs is 45.45 percent.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 47
REQUEST FOR PRODUCTION NO. 22: Please provide the supporting
workpapers for the Company's analysis used to "calibrate" the project cost estimates
against similar 500 kV projects described in Company Witness Ellsworth testimony.
Ellsworth Direct at 51.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: At the time that
PacifiCorp and BPA reviewed and calibrated the Company’s estimated costs for the
B2H project to support the B2H cost estimate in prior Integrated Resource Plans,
PacifiCorp and BPA had recently constructed the following transmission lines:
1. BPA: Lower Monumental–Central Ferry 500-kV 1 line (WA, 38 miles, in-service
2015);
2. BPA: Big Eddy–Knight 500-kV line (WA/OR, 39 miles, in-service 2016);
3. PacifiCorp: Sigurd to Red Butte 345-kV line (UT, 160 miles, in-service 2015);
4. PacifiCorp: Mona to Oquirrh 500-kV line (UT, 100 miles, in-service 2013).
Additionally, in early 2017, Idaho Power visited with NV Energy and Southern
California Edison to learn from each company’s recent experience constructing 500-kV
transmission lines in the West. As part of the discussions with each company, Idaho
Power calibrated cost estimates and resource requirements. The two projects discussed
in those meetings were:
1. NV Energy: ON Line project (NV, 235 miles, 500-kV, in-service 2014); and
2. Southern California Edison: Devers to Palo Verde (AZ, 150 miles, 500-kV, in-service
2013).
It is important to note that these discussions did not result in specific quantified
adjustments to B2H costs, but rather the information gained during these visits informed

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 48
the development and reasonableness of future B2H cost estimates.
As described in Ms. Barretto’s Direct Testimony, based on the indicative design,
Owner’s Engineer HDR, Inc. (“HDR”) utilized their utility and industry experience with
current market values for materials, equipment, and labor plus their experience with the
specific BPA towers and conductor that the B2H project is using to arrive at the 2021
IRP B2H cost estimate. HDR accomplished a partial material take off for all major items
(towers, conductors, foundations, roads, rights-of-way, etc.) using the fewest
assumptions possible. A material take off is a term used in engineering and
construction, and refers to a list of materials with quantities and types that are required
to build a designed structure or item. In 2021, Idaho Power hired the firm Leidos
Engineering, LLC (“Leidos”), to provide engineering services to develop a detailed
transmission line design for the project. In 2022, the Company hired the firm Quanta
Infrastructure Solutions Group (“QISG”) as the constructability consultant for the project.
QISG has significant and recent experience overseeing and managing construction of
high-voltage transmission projects. At the time the Company’s Application was filed,
Leidos had completed the 60 percent detailed design package, and QISG had
performed a constructability review of the design and provided a cost estimate for the
transmission line component of the project based on their expertise, for which the B2H
cost estimate was based. QISG’s significant and recent experience includes the
following recent or active projects:
- Gateway South – WY/UT, 450 miles of 500-kV
- SunZia – NM/AZ, 550 miles of 525-kV high voltage direct current
- Florida Power & Light – FL, 500 miles of 500-kV

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 49
- Aeolus to Jim Bridger – WY, 145 miles of 500-kV and 345-kV
As detailed above, the cost calibration was performed recently and informed by
recent comparable projects.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 50
REQUEST FOR PRODUCTION NO. 23: Please describe the Requests For
Proposals ("RFP") that are currently open for the B2H project. Please include the
following:
a. A description of the product or service,
b. The required date,
c. The cost,
d. The vendor selection criteria, and
e. Supporting documents and workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: 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 this request 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.
Idaho Power held Request for Information (“RFI”) events to qualify vendors prior
to moving vendors to the RFP process. Currently, there are RFP processes in progress
for multiple material packages including self-supporting steel lattice structures,
conductor, and conductor hardware. Descriptions the RFPs in process currently are
described below.
1. Self-Supporting Steel Lattice Structures

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 51
a. Description: 500-kV Self Supporting Steel Lattice Structures from
an engineered tower family developed by the Bonneville Power
Administration. Please see the Lattice folder within the DR 23
Attachments folder on the FTP site for the RFP and associated
appendices.
b. Required Date: The RFP was issued on January 12, 2023, and
closed on February 27, 2023. The team is currently evaluating
respondent proposals.
c. Cost: Because the proposals are currently in the competitive bid
process and evaluation is not complete, Idaho Power cannot
provide the cost associated with the RFP. However, at this time the
Company estimates approximately in lattice structure
costs, excluding contingency, overheads, Allowance for Funds
Used During Construction (“AFUDC”), or taxes.
d. Vendor Selection Criteria: Proposals will be evaluated on a number
of criteria, including but not limited to, ability to meet project
specifications, ability to meet project schedule, price, quality,
previous experience, and value added technical and commercial.
e. See (a).
2. Conductor
a. Description: Approximately 15,381,000 feet of 1519 aluminum
conductor steel reinforced “Deschutes” conductor. The wire system
is installed as a triple bundled configuration. Please see the

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 52
Conductor folder within the DR 23 Attachments folder on the FTP
site for the RFP and associated appendices.
b. Schedule: The RFP was issued on February 23, 2023, and is
scheduled to close on March 10, 2023.
c. Cost: Because the proposals are currently in the competitive bid
process, Idaho Power cannot provide the cost associated with the
RFP. However, at this time the Company estimates approximately
in conductor costs, excluding contingency, overheads,
AFUDC, or taxes.
d. Vendor Selection Criteria: Proposals will be evaluated on a number
of criteria, including but not limited to, ability to meet project
specifications, ability to meet project schedule, price, quality,
previous experience, and value added technical and commercial.
e. See (a).
3. Conductor Hardware
a. Description: Hardware package for hot-end assembly includes
insulators, suspension clamps, fittings, shackles, and others.
Please see the Hardware folder within the DR 23 Attachments
folder on the FTP site for the RFP and associated appendices.
b. Schedule: The RFP was issued on February 24, 2023, and is
scheduled to close on March 22, 2023.
c. Cost: Because the proposals are currently in the competitive bid
process, Idaho Power cannot provide the cost associated with the

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 53
RFP. However, at this time the Company estimates approximately
for all project hardware, including optical ground wire
hardware which will be bid out separately, but excluding
contingency, overheads, AFUDC, or taxes.
d. Vendor Selection Criteria: Proposals will be evaluated on a number
of criteria, including but not limited to, ability to meet project
specifications, ability to meet project schedule, price, quality,
previous experience, and value added technical and commercial.
e. See (a).
The response to this Request is sponsored by Joe Stippel, Principal Engineering
and Construction Project Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 54
REQUEST FOR PRODUCTION NO. 24: Please describe the RFPs that are
planned for the B2H project.
Please include the following:
a. A description of the product or service,
b. The required date,
c. The cost,
d. The vendor selection criteria, and
e. Supporting documents and workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24: 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 this request 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.
Idaho Power is holding a Request for Information (“RFI”) event to qualify vendors
before moving vendors to the RFP process. Some of the material or service packages
have started or are concluding the RFI process, including tubular steel, optical ground
wire (“OPGW”), OPGW hardware, miscellaneous hardware, and construction services.
These are to be competitively bid to qualified vendors as part of future RFP events.
Descriptions of the remaining planned RFPs are below.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 55
1. Tubular Steel
a. Description: Approximately 120 tubular steel structures that include
H-frames and 3-pole dead-ends installed on concrete foundations.
All structures to be made of weathering steel.
b. Schedule: The team has completed the RFI process and is
planning to issue the RFP around March 10, 2023, with an
expected close date of March 31, 2023.
c. Cost: Because the RFI is in the competitive bid process, Idaho
Power cannot provide specific cost information. However, at this
time the Company estimates tubular steel costs of ,
excluding contingency, overheads, AFUDC, and taxes.
d. Vendor Selection Criteria: Proposals will be evaluated on a number
of criteria, including but not limited to, ability to meet project
specifications, ability to meet project schedule, price, quality,
previous experience, and value added technical and commercial.
e. Please see the Tubular Steel - RFI folder within the DR 24
Attachments folder on the FTP site for the RFI. Note, the RFP
package is under development and not available.
2. OPGW
a. Description: Approximately 600 miles of 96-count fiber to support
two OPGW installations in the shield-wire position.
b. Schedule: The RFI was issued on February 15, 2023, and closed
on March 3, 2023. Idaho Power will evaluate responses and select

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 56
qualified vendors who will move forward to the RFP event which is
anticipated to occur around March 10, 2023. The scheduled RFP
close date is expected to be April 1, 2023.
c. Cost: Because the RFI is in the competitive bid process, Idaho
Power cannot provide specific cost information. However, at this
time the Company estimates OPGW costs of , excluding
contingency, overheads, AFUDC, and taxes.
d. Vendor Selection Criteria: Proposals will be evaluated on a number
of criteria, including but not limited to, ability to meet project
specifications, ability to meet project schedule, price, quality,
previous experience, and value added technical and commercial.
e. Please see the OPGW - RFI folder within the DR 24 Attachments
folder on the FTP site for the RFI. Note, the RFP package is under
development and not available.
3. OPGW Hardware
a. Description: Hardware to support approximately 600 miles of 96-
count fiber that supports two OPGW installations in the shield-wire
position.
b. Schedule: The RFI was issued on February 15, 2023, and closed
on March 3, 2023. Idaho Power will evaluate responses and select
qualified vendors who will move forward to the RFP event which is
anticipated to occur around March 10, 2023. The scheduled RFP
close date is expected to be April 1, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 57
c. Cost: Please see the Company’s Response to Production Request
23, part 3(c).
d. Vendor Selection Criteria: Proposals will be evaluated on a number
of criteria, including but not limited to, ability to meet project
specifications, ability to meet project schedule, price, quality,
previous experience, and value added technical and commercial.
e. Please see the OPGW Hardware - RFI folder within the DR 24
Attachments folder on the FTP site for the RFI. Note, the RFP
package is under development and not available.
4. Construction Services
a. Description: Idaho Power plans to start bidding out all construction
services, with the exception of stations construction, in the spring of
2023. The specific work packages are being developed. Stations
construction will be designed and bid out in approximately 18
months.
b. Schedule: Idaho Power is planning to begin the RFI process in
March 2023 to evaluate and qualify potential contractors before
moving them to the RFP event. The RFP event is expected to
occur in April 2023.
c. Cost: Because the competitive bid process has not yet begun,
Idaho Power cannot provide specific cost information. However, at
this time the Company estimates transmission line construction
costs of , excluding construction manager costs,

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 58
contingency, overheads, AFUDC, and taxes.
d. Vendor Selection Criteria: Proposals will be evaluated on a number
of criteria, including but not limited to, ability to meet project
specifications, ability to meet project schedule, price, quality,
previous experience, and value added technical and commercial.
e. Supporting documents are still under development and not
available at this time.
Idaho Power will likely competitively bid other services that include, but are not limited
to, a construction inspection compliance contractor, an owner’s field inspection, and
other miscellaneous services. There will be ancillary material that will also need to be
competitively bid out that may include items like miscellaneous hardware not included in
the hardware package, regeneration communication sites, 230-kV and 138-kV reroute
material, and gas-line mitigation material and services.
The response to this Request is sponsored by Joe Stippel, Principal Engineering
and Construction Project Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 59
REQUEST FOR PRODUCTION NO. 25: Please provide the scope of work for
the Hemingway substation to integrate with the new B2H transmission line. Also, please
provide worksheets with formulas intact detailing the costs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 25:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 60

.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 61
DATED at Boise, Idaho this 6th day of March 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 62
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 6th day of March 2023, I served a true and correct
copy of Idaho Power Company’s Response to the First 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
Riley Newton
Michael Duval
Deputy Attorney General
Idaho Public Utilities Commission
Po Box 83720
Boise, Idaho 83720-0074

Hand Delivered
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Overnight Mail
FAX
X E-mail [e-mail]
X FTP Site

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

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X_ FTP Site

Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Industrial Customer of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702

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Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 63
City of Boise
Ed Jewell
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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[e-mail]
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Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202

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[e-mail]
[e-mail]
[e-mail]
[e-mail]
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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
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Idaho Conservation League
Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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[e-mail]
[e-mail]
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______________________________
Stacy Gust, Regulatory Administrative Assistant