20230628IPC to Staff 1-2_6-7_9_21_30_33_37.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
June 27, 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-23-11
Idaho Power Company’s General Rate Case
Dear Ms. Noriyuki:
Enclosed for electronic filing, please find Idaho Power Company’s Response to
Requests Numbers 1, 2, 6, 7, 9, 17, 21, 30, 33, and 37 to the First Production Request of
the Commission Staff to Idaho Power Company.
Due to the collectively voluminous 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 unless otherwise noted in the response. 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 has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site has been provided the parties that have executed the
Protective Agreement in this matter.
If you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:sg
Enclosures
RECEIVED
2023 JUNE 27, 2023 4:33PM
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-23-11
In the Matter of the Application of Idaho Power Company for Authority to Increase
Its Rates and Charges for Electric Service to Its Customers In the State of Idaho
and For Associated Regulatory Accounting Treatment
The undersigned attorney, in accordance with Commission Rules of Procedure
67, believes that all of the attachments in Response to Requests Nos. 1, 6, 9, 17, 21,
and 37 to Idaho Power Company’s Response to the First Production Request of the
Commission Staff dated June 27, 2023, contain information that is a trade secret of
Idaho Power or a third party, information exempt from disclosure by federal law
(material nonpublic information under U.S. Securities and Exchange Commission
Regulation FD), and/or business records of a private enterprise required by law to be
submitted to or inspected by a public agency as described in Idaho Code § 74-101, et
seq., and/or § 48-801, et seq. As such, this information is protected from public
disclosure and exempt from public inspection, examination, or copying.
DATED this 27th day of June 2023.
LISA D. NORDSTROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
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]
[e-mail]
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE
STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY
ACCOUNTING TREATMENT.
)
)
)
)
)
)
)
)
CASE NO. IPC-E-23-11
IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“Commission” or
“Staff”) dated June 13, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 1: Please provide copies of the monthly trial
balances from January 2018 through the most current month available. Please
supplement your response when additional months become available throughout 2023.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the six
attached Confidential Excel files, and labeled:
 “Confidential Attachment 1 – Response to Staff Request No. 1 - 2018”,
 “Confidential Attachment 2 – Response to Staff Request No. 1 - 2019”,
 “Confidential Attachment 3 – Response to Staff Request No. 1 - 2020”,
 “Confidential Attachment 4 – Response to Staff Request No. 1 - 2021”,
 “Confidential Attachment 5 – Response to Staff Request No. 1 - 2022”,
 “Confidential Attachment 6 – Response to Staff Request No. 1 - 2023”.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, 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 a copy of the Company's
Chart of Accounts.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see the attached
Excel file, labeled “Attachment – Response to Staff Request No. 2”.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 6: Please provide the total amount that the
Company spent on the following activities for 2020 through 2023 to date and show how
the Company allocated the amounts between jurisdictions:
a. Internal auditing expenses;
b. The Company's annual report;
c. Rating agencies;
d. All software or information system-related issues;
e. Board of Directors compensation, travel expenses, and meeting expenses
f. Corporate or chartered aircraft(s), if applicable
g. Travel and training for all shared executives of the Company and affiliates;
h. Insurance coverage;
i. Overhead items including utilities, property taxes, security services, and other
corporate headquarter expenses; and
j. All other allocated expenses.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
a. Internal auditing expenses;
Please see the attached confidential Excel file, labeled “Confidential
Attachment – Response to Staff Request No. 6a”.
b. The Company's annual report;
A response to subpart b. will be provided on, or before July 5th.
c. Rating agencies;
Please see the attached confidential Excel file, labeled “Confidential
Attachment – Response to Staff Request No. 6c”.

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

d. All software or information system-related issues;
Please see the attached confidential Excel file, labeled “Confidential
Attachment – Response to Staff Request No. 6d”.
e. Board of Directors compensation, travel expenses, and meeting expenses
Please see the attached confidential Excel file, labeled “Confidential
Attachment – Response to Staff Request No. 6e”.
f. Corporate or chartered aircraft(s), if applicable
Please see the attached confidential Excel file, labeled “Confidential
Attachment – Response to Staff Request No. 6f”.
g. Travel and training for all shared executives of the Company and affiliates;
A response to subpart g. will be provided on, or before July 5th.
h. Insurance coverage;
Please see the attached confidential Excel file, labeled “Confidential
Attachment – Response to Staff Request No. 6h”. Please note that the
amounts do not include Wildfire Mitigation Deferrals or Damage Claims
related expenses.
i. Overhead items including utilities, property taxes, security services, and other
corporate headquarter expenses; and
A response to subpart i. will be provided on, or before July 5th.
j. All other allocated expenses.
The Company is uncertain what is meant by “all other allocated expenses.”
However, the Company interprets the request as asking the Company to identify any
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
allocated expenses from IDACORP, or its subsidiaries to Idaho Power. To this end, there
are not any allocated expenses from IDACORP, or its subsidiaries to Idaho Power.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 7: Please provide a copy of all regulatory
orders relating to the Company or its subsidiaries issued by state agencies in Oregon or
the Federal Energy Regulatory Commission ("FERC") in 2021 through 2023 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: Please see the seven
attached PDF files labeled:
 “Attachment 1 – Response to Staff Request No. 7 - 2021 FERC Orders”,
 “Attachment 2 – Response to Staff Request No. 7 - 2022 FERC Orders”,
 “Attachment 3 – Response to Staff Request No. 7 - 2023 FERC Orders”,
 “Attachment 4 – Response to Staff Request No. 7 - 2023 EFSC Order”,
 “Attachment 5 – Response to Staff Request No. 7 – 2021 OPUC Orders”,
 “Attachment 6 – Response to Staff Request No. 7 – 2022 OPUC Orders”,
 “Attachment 7 – Response to Staff Request No. 7 – 2023 OPUC Orders”.
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 9: Please provide a matrix identifying the
major capital expenditure approval levels that includes the dollar level of authorization by
employee title, division, and company. Please include within your response the dollar
level at which the individual capital expenditures require approval by the Company's
Board of Directors ("Board of Directors").
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Please see the
confidential Excel filed attached labeled Confidential Attachment – Response to Staff
Request No. 9 for a list of approval authority levels. Any individual project which meets
either of the following criteria must be specifically approved by the Board.
 will cost more than $4 million during the current budget year, or
 has a total cost greater than $15 million including prior periods and will cost
more than $4 million in total during the current and future budget years.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 17: Please provide copies of all Audit
Reports issued by the Company's internal auditors for all audits completed during 2021
through 2023 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Audit Services has
summarized audits completed during the period requested in the below table. All Audit
Reports for Idaho Power for the period 2021 through 2023 to date are listed with
corresponding page numbers to the supporting PDF.
Audit reports and management responses are only issued for SOX internal control
audits in the event of a finding(s). No SOX testing has been performed in 2023 as of the
date of this response. Audit reports are included for all Operational and Information
Technology audits completed during the period.
Audit Services performs some audits of subsidiaries that do not directly relate to
Idaho Power and has not provided those reports nor included them in the table below.
Audit Services performs some audits at the direction of Idaho Power’s Legal
Department under attorney/client privilege and has not provided those reports nor
included them in the below table.
The requested Audit Reports are proprietary and confidential. The response to this
Request is sponsored by Paula Jeppsen, Forecasting and Planning Director, Idaho Power
Company.
PDF
Page
#'s
Year
Issue
d Audit
Type

Audit
Number Audit Name
1-3 2021 Operation
al/IT 201904 SAP Application Controls - EDM HSB
4-8 2021 Operation
al/IT 201908 Disaster Recovery Non-IT Managed
9-12 2021 Operation
al/IT 201914 Co-Generation & Small Power Production Contracts
13-14 2021 Operation
al/IT 201921 Project Management - GE Grid Solutions

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
15-17 2021 Operation
al/IT 201922 Power Production Engineering & Construction - Voith Hydro Contract-Lower Salmon
18-22 2021 Operation
al/IT 201925 Garage - Les Schwab Contract Audit
23-26 2021 Operation
al/IT 202009 Incentive Plans - IDACORP
27-29 2021 Operation
al/IT 202014 Corporate Contributions - Employee Community Funds
30-33 2021 Operation
al/IT 202015 Procurement and Contracting - Meyer
34-36 2021 Operation
al/IT 202022 Information Management Follow-Up Audit
37-38 2021 Operation
al/IT 202023 Integrated Resource Plan (IRP) - Load Forecasting Follow-Up Audit
39-42 2021 Operation
al/IT 202024 Disaster Recovery Follow-Up Audit
43-45 2021 Operation
al/IT 202111 IT Software License Guidelines - Software Licensing Review Follow-Up Audit
46-47 2021 Operation
al/IT 202123 Procurement and Contracting - Meyer Follow-Up Audit
48-50 2021 Operation
al/IT 202126 Audit Services Quality Assurance and Improvement Program (QAIP)
51-52 2021 SOX BSIB Blue Shield - IBNR
53-55 2021 SOX FACW Fixed Assets Capital Work Orders
56-57 2021 SOX ITCF IT Configuration Management
58-61 2021 SOX ITCH IT Change Management
62-64 2021 SOX ITSS IT System Security
65-67 2022 Operation
al/IT 202008 Vegetation Management - Tree Trimming Contracts Audit
68-71 2022 Operation
al/IT 202101 Valmy Operating Agreement Audit
72-73 2022 Operation
al/IT 202102 Bridger Operating Agreement Audit
74-76 2022 Operational/IT 202105 SAP Application Controls - Upgrades
77-79 2022 Operation
al/IT 202106 Cyber Security Monitoring Event Investigation and Reporting
80-82 2022 Operation
al/IT 202108 Power Transactions - REC Tracking
83-85 2022 Operation
al/IT 202110 Joint Use Agreements Follow-Up Audit
86-88 2022 Operation
al/IT 202115 Executive Perquisites Audit
89-91 2022 Operation
al/IT 202116 Incentive Plans - IDACORP
92-94 2022 Operation
al/IT 202118 Corporate Contributions - Idaho Power Foundation
95-97 2022 Operation
al/IT 202120 Power Production Engineering & Construction - Hells Canyon Generator
Refurbishments Contract
98-
102 2022 Operation
al/IT 202122 Procurement and Contracting - McFarland Cascade Holdings (Stella Jones)
103-
104 2022 Operation
al/IT 202127 Data Analytics - Vendor Master File
105-
108 2022 Operation
al/IT 202201 Valmy Operating Agreement Audit
109-
111 2022 Operation
al/IT 202210 Garage - Les Schwab Follow-Up Audit
112-
114 2022 Operation
al/IT 202218 EIM Operations - Self Audit Attestation
115-
117 2022 Operation
al/IT 202224 Audit Services Quality Assurance and Improvement Program (QAIP)
118-
119 2022 SOX CRIT Customer Revenues IT Process

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
120-
121 2022 SOX CRUR Customer Revenues Unbilled Revenues Estimate
122-
123 2022 SOX ETBO Energy Transactions Balancing Operations
124-
125 2022 SOX EWIC Entity-Wide Information & Communication
126-
127 2022 SOX ITMD IT Manage Data
128-
129 2022 SOX ITSS Information Technology System Security
130-
133 2022 SOX PEAR Pervasive Axxess Reviews
134-
135 2022 SOX PPPP Payrol Processing
136-
140 2023 Operation
al/IT 202012 Day Ahead - Balancing Operations
141-
142 2023 Operation
al/IT 202202 Bridger Operating Agreement Audit
143-
145 2023 Operation
al/IT 202203 Incentive Plans - IDACORP
146-
149 2023 Operation
al/IT 202209 Co-Generation & Small Power Production Contracts Follow-Up Audit
150-
152 2023 Operation
al/IT 202211 Disaster Recovery Non-IT Managed Follow-Up Audit
153-
155 2023 Operation
al/IT 202215 Application Development – My Account and Mobile Application

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
REQUEST FOR PRODUCTION NO. 21: For each officer of the Company, please
provide the total dollar amount of remuneration for 2018 through 2023 to date. Please
separate by year, salary, incentive pay, options, benefits, and other. For each officer,
please provide the percentages of his or her total remuneration that is allocated to other
subsidiaries each year along with the basis for that allocation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: For the requested
details related to officer compensation, please see the Confidential Excel file attached,
labeled “Confidential Attachment - Staff Request No. 21 - Officer Compensation 2018-
2023”. The basis for the allocation between Idaho Power, IDACORP, and Idaho Financial
Services is actual labor entry related to work performed for each entity.
The response to this Request is sponsored by Sarah Griffin, Vice President of
Human Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
REQUEST FOR PRODUCTION NO. 30: Please provide a copy of the Company's
property tax bills for 2021 through 2023 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 30: Idaho Power’s property
tax bills are too voluminous to provide copies. All property tax bills will be made available
for review onsite. The property tax bills will be made available for Staff audit at Idaho
Power's corporate headquarters. Please contact Tami White at [phone] or David
Fewkes at [phone] to arrange a time to review the requested material.
The response to this Request is sponsored by Paula Jeppsen, Planning and
Forecasting Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
REQUEST FOR PRODUCTION NO. 33: Please summarize all the Company's
penalties or fines paid in 2021 through 2023 to date. Please show all account numbers
and the amount booked to each by occurrence and date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 33: The below table shows
the penalties and fines paid between January 1, 2021 and May 31, 2023. Please note
that these items are not included in Idaho Power’s request for recovery in rates.
Account Amount Paid Transaction Date Vendor
426300
5,000.00 9/14/2021 STATE OF IDAHO BUILDING SAFETY
426300
506.21 1/3/2023 ADA COUNTY TREASURER
426300
2,250.00 1/6/2023 OREGON DEPARTMENT CONSUMER AND
BUSINESS SERVICES
426300
80.23 1/4/2023 CLARK COUNTY
426300
1,019,200.00 9/12/2022 STATE OF IDAHO
426300
72,800.00 10/4/2022 STATE OF IDAHO

The response to this Request is sponsored by Paula Jeppsen, Planning and
Forecasting Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
REQUEST FOR PRODUCTION NO. 37: Please provide copies of the monthly,
quarterly, and annual comparisons of operating and capital budget to actual expenditures
for 2018 through 2023 to date. Please include within your response a narrative
explanation for budget variations. This should include, but not be limited to, written
operating and capital budget variance reports and explanations used by Company officers
and managers to monitor and control budgets under their responsibility. Please
supplement your response as additional information becomes available throughout 2023.
RESPONSE TO REQUEST FOR PRODUCTION NO. 37: Please see the six
attached Confidential PDF files, and labeled:
 “Confidential Attachment 1 – Response to Staff Request No. 37 - 2018”,
 “Confidential Attachment 2 – Response to Staff Request No. 37 - 2019”,
 “Confidential Attachment 3 – Response to Staff Request No. 37 - 2020”,
 “Confidential Attachment 4 – Response to Staff Request No. 37 - 2021”,
 “Confidential Attachment 5 – Response to Staff Request No. 37 - 2022”,
 “Confidential Attachment 6 – Response to Staff Request No. 37 - 2023”.
The current variance reporting process was initiated in February 2018, therefore,
January 2018 is unavailable. Additionally, the variance reporting for May 2019 cannot
be retrieved and is also unavailable.
The response to this Request is sponsored by Paula Jeppsen, Planning and
Forecasting Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
DATED at Boise, Idaho, this 27th day of June 2023.

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 27th day of June 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
Dayn Hardie
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

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]

Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]
[e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18

Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

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

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

Hand Delivered
U.S. Mail
Overnight Mail
FAX
_ FTP Site
X Email [e-mail]
[e-mail]
[e-mail]

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]

Stacy Gust, Regulatory Administrative
Assistant