20230705IPC to Staff 3-6_8_10-16_18-20_22-29_31-32_34-36.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

July 5, 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 3, 4, 5, 6, 8, 10, 11, 12, 13, 14, 15, 16, 18, 19, 20, 22, 23, 24, 25, 26,
27, 28, 29, 31, 32, 34, 35, and 36 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 JULY 5, 2023 4:44PM
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. 5, 6g, 6i,13, 14, 19,
20, 22, 24, 25, 26, 32, and 36 to Idaho Power Company’s Response to the First
Production Request of the Commission Staff dated July 5, 2023, contain information that
Idaho Power Company and a third party claim are trade secrets, business records of a
private enterprise require by law to be submitted to or inspected by a public agency,
and/or public records exempt from disclosure by state or federal law (material nonpublic
information under U.S. Securities and Exchange Commission Regulation FD) as
described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected
from public disclosure and exempt from public inspection, examination, or copying.

DATED this 5th day of July, 2023.

LISA D. NORDSTROM
Counsel 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.
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)
)
)
)
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)
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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. 3: Please provide all workpapers and exhibits
in Excel format with formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The workpapers and
exhibits were provided to the Commission on June 7, 2023.
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 - 3
REQUEST FOR PRODUCTION NO. 4: Please provide the revenue requirement
model in Excel format with formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see the Excel file
attached, labeled “Attachment – Response to Staff Request No. 4_Exhibit 35 – JSS –
2023 Test Year.”
The response to this Request is sponsored by Kelley Noe, Regulatory Consultant,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 5: Please provide a list of all outside
attorneys who performed services for the Company or who were paid by the Company
for services from the beginning of 2021 through 2023 to date. Please list the amounts
paid, accounts charged, and date of payment.
Please also provide a brief summary of the services performed. Additionally, if
services were performed in support of a docketed federal/state court or regulatory action,
please identify the case name, case number, and jurisdiction. For each expense, please
illustrate how the charge was allocated to the Company's jurisdictions.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the Excel file
attached, labeled “Confidential Attachment 1 - Response to Staff Request No. 5 - Damage
Claims Outside Attorney Fees” for a list of outside attorneys who were paid by the
Company for services related to damage claims, from January 1, 2021, through May 31,
2023, including the amounts paid, accounts charged and a brief summary of the services
performed.
Additionally, please see the file labeled “Confidential Attachment 2 - Response to
Staff Request No. 5 - External Legal” for a list of outside attorneys who were paid by the
Company for all other legal services from January 1, 2021, through May 31, 2023,
including the amounts paid, accounts charged, and a brief summary of the services
performed. Account 107 is construction work-in-progress (“CWIP”), which is not included
in rate base. Several of the capital projects included in this response that have incurred
outside legal fees are not yet in service (i.e., not requested for recovery in this case)
including B2H and Hells Canyon Relicensing.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
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 - 6
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:
b. The Company's annual report;
Year Idaho Power
Expense
Idaho
Jurisdictional
Allocation
Idaho
Jurisdictional
Share
2023 $ 48,241 95.64% $ 46,138
2022 36,378 95.64% 34,972
2021 28,911 95.64% 27,650
2020 23,166 95.64% 22,156

g. Travel and training for all shared executives of the Company and affiliates;

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
Travel and training O&M expenses for Idaho Power Company executives that were
also IDACORP, Inc. executives from January 1, 2020, through May 31, 2023, are included
within the detail of company vehicles, other transportation expense, personal vehicles,
business meals, lodging, airfare, service club and employee memberships, and
registration fees, professional memberships and licenses cost elements as shown in
'Confidential Attachment - Response to Staff Request No. 6g'. Corporate airplane
expenses associated with Idaho Power Company executives that were also IDACORP,
Inc. executives from January 1, 2020, through May 31, 2023, have not been included in
the 'Confidential Attachment - Response to Staff Request No. 6g' as corporate airplane
expenses are separately provided as part of the response to Request No. 6f. This detail
includes transactions that were removed from the 2022 base financial information, as
described in Paula Jeppsen Exhibit No. 23, Pages 4-9.
i. Overhead items including utilities, property taxes, security services, and other
corporate headquarter expenses.
Please see the confidential attachment labeled “Confidential Attachment -
Response to Staff Request No. 6i”.
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 - 8
REQUEST FOR PRODUCTION NO. 8: Please provide access to all employee
newsletters published in 2021 through 2023 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Please see the PDF files
attached labeled “Attachment 1 – Response to Staff Request No. 8_2021 News Scans,”
“Attachment 2 – Response to Staff Request No. 8_2022 News Scans,” and “Attachment
3 – Response to Staff Request No. 8_2023 News Scans.”
The response to this Request is sponsored by Erica Shiflet, Corporate
Communications Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 10: Please provide an analysis of any sales
of land and/or plant for the years 2021 through 2023 to date, if any. Please show gains,
losses, and supporting documentation including accounting entries for removal of items
from rate base.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: From 2021 through May
31, 2023, Idaho Power had one property sales transaction that was the result of a road
widening project. On December 17, 2021, the Ada County Highway District acquired a
strip of Idaho Power land located at the Hillsdale substation to allow for the installation of
a roundabout at the intersection of Eagle and Amity Roads in Ada County. Following this
sale, Idaho Power retired the land and associated site improvements from plant reflecting
net gains within FERC account 421.1 Gain on Disposition of Property and 108
Accumulated Provision for Depreciation of Electric Plant in Service, respectively. The
entries booked for this sale transaction are summarized below.
Dr. 131 Cash 8,813.00
Cr. 101 Electric Plant In Service (1,588.94)
Cr. 421.1 Gain on Disposition of Property (7,224.06)
To record the sale of land and the associated gain resulting from proceeds in
excess of historical cost within FERC account 421.1.
Dr. 131 Cash 5,977.00
Cr. 101 Electric Plant In Service (4,972.22)
Cr. 108 Accumulated Provision for Depreciation (1,004.78)
To record the sale of land improvements with the variance in sale proceeds and
historical cost reflected in FERC account 108.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
In accordance with the accounting information detailed above these amounts are
not included in the Company’s 2023 test year.
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 - 11
REQUEST FOR PRODUCTION NO. 11: Please provide the details of any planned
sales of land and/or plant for the remainder of 2023 through 2025. Please include within
your response the estimated date of these sales and planned accounting treatment.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: At this time, there are
two potential sales transactions that Idaho Power is considering for the remainder of 2023
through 2025.
1. Ritter Island Land – This transaction is currently under review as part of a pending
case (No. IPC-E-23-07) with the Idaho Public Utilities Commission. The
anticipated retirement of the Ritter Island land is included within the Company’s
2023 test year plant activity and is therefore excluded from the Company’s rate
base in this case.
2. Donnelly McCall Transmission Land – Idaho Power has been contacted by an
adjacent landowner seeking to purchase 1.23 acres of transmission land in Valley
County. The Company is evaluating the potential sale of this land, while still
retaining easement rights for future transmission needs. To record the
conveyance of land, the original cost of $1,320.05 would be removed from FERC
account 105 Electric Plant Held for Future Use. Any proceeds above and beyond
the original cost would be applied to FERC account 411.6 Gain from Disposition
of Utility Plant. Estimated proceeds are not expected to exceed $8,000 and the
estimated timing of sale could be around November 2023, allowing time for Idaho
Public Utilities Commission review and consideration as part of a separate case
filing should the sales transaction be pursued.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
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 - 13
REQUEST FOR PRODUCTION NO. 12: Please provide a list of "out-of-period
adjustments" and "extraordinary items" for the years 2021 through 2023 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: For the years 2021
through 2023 to date, there were no “out-of-period adjustments”, except those identified
in the Company’s response to Request No. 18. There were no “extraordinary items” for
the years 2021 through 2023 to date.
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 - 14
REQUEST FOR PRODUCTION NO. 13: Please provide a schedule showing
injuries and damages claims over $1,000 for the years 2021 through 2023 to date. Please
include within your response the description of each item, the amount for each item, and
the account charged.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: Please see the attached
confidential Excel file, labeled “Confidential Attachment – Response to Staff Request No.
13”.
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 - 15
REQUEST FOR PRODUCTION NO. 14: Please provide the details of all
advertising expenses recorded above the line including account and subaccounts where
posted, dates posted, vendor names, explanations, and amounts posted during 2021
through 2023 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: Please see ‘Confidential
Attachment - Response to Staff Request No. 14’ for all advertising O&M expenses,
including description, date, and account posted from January 1, 2021, through May 31,
2023. Advertising expenses charged to Account 930100 were removed entirely from the
rate case request. See Paula Jeppsen Exhibit No. 23, Page 1. These amounts include
advertising expenses associated with employment recruiting.
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 - 16
REQUEST FOR PRODUCTION NO. 15: Please provide copies of all
advertisements used during 2021 through 2023 to date and correlate the advertisement
with the specific detail provided in the Company's response to Request No. 13.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Please see the files
attached (Attachments 1 – 119) for all advertisements. “Attachment 1 - Response to Staff
Request No. 15 Finance Details 2021-2023” shows the details also provided with Request
No. 14. The correlating ads can be found either in the corresponding PDF for a particular
year (“Attachment 02 – Response to Staff Request No. 15 2021AdsWithCharges,”
“Attachment 39 – Response to Staff Request No. 15 2022AdsWithCharges,” and
“Attachment 84 – Response to Staff Request No. 15 2023AdsWithCharges”) or in the
individual attachments with the corresponding file name as indicated in the Excel
spreadsheet in Attachment 1.
Additional advertisements are provided that do not have above the line charges.
The response to this Request is sponsored by Erica Shiflet, Corporate
Communications Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
REQUEST FOR PRODUCTION NO. 16: Please provide copies of all billing inserts
for 2021 through 2023 to date. Please indicate the states where they were sent. Please
also provide a schedule showing the amount and account numbers charged for all costs
to produce, print, and distribute the inserts.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Please see the Excel
and PDF files attached labeled “Attachment 1 – Response to Staff Request No. 16
Finance Details,” “Attachment 2 – Response to Staff Request No. 16 2021 Bill Inserts,”
“Attachment 3 – Response to Staff Request No. 16 2022 Bill Inserts,” and “Attachment 4
– Response to Staff Request No. 16 2023 Bill Inserts.” Each bill insert on the Excel
spreadsheet references a page number in the PDF that corresponds to the year of the
insert.
The response to this Request is sponsored by Erica Shiflet, Corporate
Communications Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
REQUEST FOR PRODUCTION NO. 18: Please provide a copy of each adjusting
journal entry proposed by the Company's independent auditors in the last two audits of
the Company. Please include within your response the documentation supporting these
adjustments, and the documentation supporting any items that the Company decided not
to adjust that are not reflected in the Company's financial records and/or financial
statements.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: Through the 2022 and
2021 annual integrated financial statement audits, the Company’s independent auditors,
Deloitte & Touche LLP, did not propose any adjusting journal entries that were not already
identified through the Company’s own internal control processes. The following adjusting
journal entries that were identified through the Company’s internal control processes but
not initially recorded by the Company nor reflected in the Company’s financial records
and/or financial statements for the respective years. These entries were recorded in the
associated subsequent quarter.
 December 2022
 Western Energy Imbalance Market invoice timing - Idaho Power receives
weekly invoices from the California Independent System Operator (CAISO) for
activity related to Idaho Power’s participation in the energy imbalance market
in the western United States (“Western EIM”). These invoices contain activity
on a one-to-two-week lag, with additional true-ups continuing for several
months on subsequent invoices. Idaho Power is required to allocate portions
of the invoice to certain transmission customers. Idaho Power’s accounting
policy is to record the activity from the invoice in the period the invoice is

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19
received.
Due to an increase in Western EIM volumes and historically volatile energy
prices in December 2022, the amounts on the January 2023 invoices related
to December 2022 were larger than typical true-up amounts. Because Idaho
Power did not record this activity in December 2022, it resulted in an
understatement of purchased power expense, transmission wheeling
revenues, accounts payable, accounts receivable, power cost adjustment
(“PCA”) regulatory asset, and the PCA income statement impact. The adjusting
entry to record the activity would be as follows (in thousands):
Purchased power expense $ 5,671
Accounts payable $ (5,671)
Accounts receivable $ 2,276
Operating revenues $ (2,276)
Regulatory assets $ 5,112
Power cost adjustment (income statement) $ (5,112)
The net after-tax impact would have increased Idaho Power’s net income by
$1.3 million, which management determined was immaterial. These amounts
were recorded in the first quarter of 2023.
 December 2021
Quarterly accounts payable cut-off procedures - On a quarterly basis, as part of Idaho
Power’s control framework, Financial Accounting personnel work with Company
personnel to accrue for services performed or supplies received before the balance sheet
date for which payment has not been made or for which invoices have not been received.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 20
Also, Accounts Payable reviews invoices received after closing to determine whether they
should have been accrued in the reporting period. For the fourth quarter of 2021, these
processes resulted in the identification of transactions that were over-accrued and
transactions that were under-accrued. The net of these transactions is reflected in the
adjusting entry below (in thousands).
Accounts payable $ 74
Other operations and maintenance $ 272
Fleet clearing accounts $ 559
Construction work in progress $ (905)
 Work order not placed in service - An environmental project was completed
during the year in 2021 but the work order did not get placed in service for
accounting purposes. The entry to place the work order in service is as follows
(in thousands):
Plant in service $ 856
AFUDC $ 54
Construction work in progress $ (910)
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 - 21
REQUEST FOR PRODUCTION NO. 19: Please provide a list of all leased items
from 2021 through 2023 to date. Please separate capital leases from operating leases
and show the dates, terms, amounts, and accounts used for each lease.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: To account for leases
in accordance with accounting principles generally accepted in the United States of
America (“GAAP”), Idaho Power follows the provisions of Accounting Standards
Codification (“ASC”) 842. Under ASC 842, Idaho Power does not have any material
agreements that qualify as capital or operating leases in the requested time period. Idaho
Power does, however, maintain listings of agreements that it is required to provide to state
taxing jurisdictions for property tax purposes. A summary of information from these
listings is included in the attached confidential Excel file, labeled “Confidential Attachment
– Response to Staff Request No. 19”. These listings exclude easements or month-to-
month construction equipment rentals as the Company does not have GAAP or tax
reporting requirements for those types of agreements and, as a result, the Company does
not maintain complete listings of such agreements.
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 - 22
REQUEST FOR PRODUCTION NO. 20: Please provide a schedule of prepaid
items for 2021 through 2023 to date showing amounts posted, vendor names,
explanations, and accounts to which these items were booked. Please include within your
response any significant changes to prepaid items occurring or planned to occur in 2023
and 2024.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Please see
“Confidential Attachment - Response to Staff No. 20”. The Company is not currently
aware of any current or upcoming significant changes to prepaid items. Prepaid amounts
are not included in the rate case request.
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 - 23
REQUEST FOR PRODUCTION NO. 22: Please provide the following monthly
direct labor related information as recorded for 2018 through 2023 to date. Information,
where applicable, should be listed by O&M expense, other expense, construction and
other account groups (listed by functional categories, i.e., generation, transmission,
distribution, customer, A&G, etc.). Please provide the information on a system-wide basis,
and jurisdiction basis. The response should include wages and salaries for each
employee category (officer, exempt, non-exempt, and union), paid time-off, overtime,
bonuses, incentive pay, and overheads for pension, benefits, and payroll taxes. Please
also include average and year-end number of employees by employee category. Include
part-time and temporary employees as full-time equivalents.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: Please see “Confidential
Attachment - Response to Staff Request No. 22”.
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 - 24
REQUEST FOR PRODUCTION NO. 23: Please provide the quantifiable savings
from any cost/workforce reduction programs during the past five years. Please provide
any additional workforce reduction programs planned for the remainder of 2023 through
2025.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: Workforce reduction is
not a reasonable assumption for a growing utility like Idaho Power; however, Idaho Power
diligently manages its workforce and associated cost. Because Idaho Power has been in
a growth period over the last five years, cost savings resulting from diligent workforce
management represent more of an avoided cost than a cost reduction.
Idaho Power applies a consistent practice of evaluating every vacant position
before refilling. The outcomes of these evaluations include positions not being filled,
positions being repurposed or filled differently, or replaced in the same capacity. This has
allowed the Company to have a relatively stable level of headcount since the last General
Rate Case (“GRC”) despite significant customer growth and necessary changes to how
Idaho Power must operate in an evolving energy landscape. By repurposing positions,
the Company has been able to adapt to technology and business process modifications
with minimal need for net-new headcount. The Company’s efforts related to workforce
management have significantly benefited customers by helping delay a GRC for 12 years,
and the practice will continue into the future as part of our overall focus on managing
costs.
As mentioned, quantifying this is difficult but the overall headcount numbers are a
compelling demonstration of these efforts. Managing the size of the workforce since 2011
has been very challenging as our number of customers has grown by over 26 percent. In

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 25
August of 2011, when the last GRC was being processed, the Company had 2,073
employees. In March of 2023 when the company calculated the payroll estimate for the
current filing, there were 2,075 employees, an addition of only two employees. If the
workforce would have grown at the same pace as customer growth over the last 12 years,
the Company’s workforce would have increased by 539 employees. This demonstrates
Idaho Power’s ongoing focus and diligence related to managing its labor resources.
The response to this Request is sponsored by Sarah Griffin, VP Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 26
REQUEST FOR PRODUCTION NO. 24: Please provide the yearly percentage
pay rate increase by employee and position since the last general rate case. Please
provide in Excel format with formulas intact.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24: Please see the
attached Excel file, labeled “Confidential Attachment – Response to Staff Request No.
24.” The attachment includes active employees of Idaho Power from January 2012 to
June 2023, excluding seasonal employees as they are not eligible for pay increase. The
increase percentage information is reported by employee, as that is consistent with how
Idaho Power tracks pay rate increases. There is data for any year that the employee was
an active employee of the Company.
Annual pay increase percentages will vary based on several factors. All
employees are eligible for an annual General Wage Adjustment (“GWA”), employees who
are still progressing to the top of their pay grade (median of market) are eligible for Merit
Salary Increases (“MSI”) every six months until they reach top of grade. Employees may
have an increase due to promotional opportunities, either through a competitive process
or promotion within a job family. Employees can also experience a reduction in pay based
on movement to a lower paying role, demotion based on performance, or when a market
evaluation results in a grade decrease.
It is important to note that the percentage changes in pay reflected in the
attachment do not have a direct correlation with a change in total labor costs because of
employee turnover and other factors.
The response to this Request is sponsored by Sarah Griffin, VP Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 27
REQUEST FOR PRODUCTION NO. 25: Please summarize all benefit and
retirement plans provided to any classification of Company employees. Please also
include any changes that have occurred to the benefits/accruals during the past five
years.
RESPONSE TO REQUEST FOR PRODUCTION NO. 25: Please see the
attached PDF file, labeled “Confidential Attachment – Response to Staff Request No. 25”.
The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 28
REQUEST FOR PRODUCTION NO. 26: Please provide copies of the Company's
pension and actuarial reports for the years 2018 through 2023 to date. Also, please
provide any actuarial calculations and documentation that show the development of FAS
87 expenses (ASC 715 Compensation - Retirement Benefits as codified), Company
contributions, balances, and assumptions.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26: Please see the three
attached confidential files which include actuarial valuation and accounting disclosure
reports from Milliman for the Company’s pension plan for the years 2018 through 2022
along with Milliman’s cover letter (Confidential Attachment 1 - Response to Staff Request
No. 26) regarding the use of its reports. These confidential reports are being provided
subject to the Protective Agreement.
For context, the actuarial valuation reports (Confidential Attachment 2 - Response
to Staff Request No. 26, in chronological order) are prepared by Milliman and provided to
the Company during the year to which each one pertains and are dated January 1 of their
respective years. The actuarial valuation report as of January 1, 2023, has not yet been
completed by Milliman but will be provided once it becomes available. Among other
information these actuarial valuation reports include the development of net periodic
pension cost (SFAS 87 expense), amounts contributed during the year, and description
of the plan’s actuarial assumptions.
The accounting disclosure reports (Confidential Attachment 3 - Response to Staff
Request No. 26, in chronological order) are prepared and provided to the Company by
Milliman in January of the year following the year to which they pertain and provide the
balances for purposes of recording the GAAP funded status of the plan along with a

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 29
preliminary estimate of the net periodic pension cost for the subsequent year. The
accounting disclosure report for 2023 will not be completed until January 2024.
As a reminder, and as described in the Direct Testimony of Company witness
Matthew T. Larkin, Idaho Power’s recovery of pension costs is based upon cash
contributions to the plan. SFAS 87 expense is deferred to a regulatory asset and does
not directly impact the income statement or the Company’s revenue requirement.
Recovery of pension costs is based upon amortization from the Company’s pension
contribution balancing account.
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 - 30
REQUEST FOR PRODUCTION NO. 27: Please provide access to the Board of
Directors' meeting minutes for each meeting held during 2020 through 2023 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27: The requested
information is highly confidential. It will be made available to Staff 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 Cheryl Thompson, Lead Counsel
and Deputy Corporate Secretary, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 31
REQUEST FOR PRODUCTION NO. 28: Please provide copies of the Board of
Directors' materials distributed for/at meetings held from 2020 through 2023 to date.
Please also include the same for the Compensation Committee.
RESPONSE TO REQUEST FOR PRODUCTION NO. 28: The requested
information is highly confidential. It will be made available to Staff 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 co-sponsored by Sarah Griffin, VP Human
Resources, Idaho Power Company, and Cheryl Thompson, Lead Counsel and Deputy
Corporate Secretary, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 32
REQUEST FOR PRODUCTION NO. 29: To the extent not previously included in
the Company's responses to these Staff Production Requests, please provide access to
copies of all studies used to determine employee compensation, including executive
compensation, and explanations of how the Company applied them in the years 2020
through 2023 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 29: The survey data
supporting the studies is provided only to companies that participate in the surveys
conducted by independent consulting firms and that information/data is considered the
confidential and proprietary work product of the consulting firms and will be made
available for review on-site. Additionally, all internal compensation studies, as described
below, are considered highly confidential and will be made available for review on-site.
Please contact Tami White at [phone] or David Fewkes at [phone] to
arrange a time to review the requested material.
The following is an overview of the compensation setting processes and studies
that the Company performs to determine appropriate and competitive compensation
levels and an overview of the philosophy and methodology associated with each process.
General Wage Adjustment (“GWA”) – Each year the Company reviews numerous
data sources and other factors to help determine the annual GWA recommendation.
These include salary surveys, union contracts, cost of living and Idaho economic factors,
recruiting and retention concerns, as well as exit interview data. The Company’s analysis
incorporates all this information and is presented to the Compensation and Human
Resources Committee of the board of directors in November of each year. Once the
recommendation is approved by the Committee, the GWA is applied to all eligible

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 33
employee’s wages for the first applicable paycheck of the new year. GWA analyses from
2020 to 2023 will be made available for on-sight review.
Employee Job Profile Reviews – Idaho Power proactively reviews existing jobs
within the Company to ensure positions remain on-market with wages, as well as to
address any recruiting and retention concerns. The Company also reviews newly
requested jobs that come at the recommendation of the internal Compensation Review
Committee (“CRC”). During a job profile review, Idaho Power works with the group
leader(s) to evaluate the job description, physical requirements, competencies, and
wages for the role. Following the wage review, any applicable grade changes are applied
to the impacted employees. If the result is a grade increase to the role, employees who
are not yet at the top of their grade will generally move laterally pay-wise into the new
grade and remain on their current merit schedule. Employees at top of their grade and
performing well are eligible for a pay increase as of the effective date of the change. If the
result is a grade reduction, impacted employees enter a Reduction in Grade (“RIG”)
program, which varies based on the situation. The Company documents each
recommendation with a ‘Decision Memo’ that contains information for the review/request,
market data, internal equity, and often includes specific employee information.
Executive Compensation Annual Review – An annual market review for each
officer position is presented to the Compensation & Human Resources Committee of the
board of directors in November. The market compensation analysis is used to determine
a market compensation range for each of the executive officers for base salary, short-
term incentive compensation, and long-term incentive compensation. The survey data
reviewed is comprised of three separate sets of company types (peer group, Investor-

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 34
Owned Utility (“IOU”) group, and general industry) for each executive officer (where data
is available). Next, each element of compensation is reviewed (including the total target
direct compensation) for each of the executive officers to ensure it is within the targeted
range of 85 to 115 percent of the median of each data set.
An individual executive officer’s compensation may be positioned above or below
the market level based on several factors such as: level of experience, responsibility,
performance, the degree of comparability between Idaho Power’s executive officer role
and the roles of persons with similar positions within the review set of companies, and
internal equity considerations. The Compensation and Human Resources Committee of
the board of directors uses its judgment and the feedback from Idaho Power’s Chief
Executive Officer on executive officer performance in assessing these factors to
determine how an executive officer's compensation should align relative to the market
level. Compensation recommendations are not made until the February meeting,
following the calendar year to assess each officer’s performance and goal completion.
Any compensation changes are then processed with a retroactive effective date to the
beginning of the year.
Senior Manager Biennial Wage Review –A biennial wage review is completed for
all senior manager and attorney positions. This is a process where, similar to the
employee job profile reviews, Human Resources engages leadership in the survey match
validation process before gathering market data. Once the market data is assembled,
base salary, short-term incentive target, long-term incentive target, total target cash, and
total target direct compensation are reviewed/analyzed to determine if the Company’s
positions are leveled and compensated appropriately. Any potential changes are

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 35
discussed with executive leadership to determine next steps and to further evaluate other
factors such as internal equity, recruiting, or retention concerns. If there are any
compensation and leveling changes, they are implemented with the upcoming year’s
compensation recommendations which occurs in February, alongside the officer
compensation changes. The most recent reviews were completed in 2020 and 2022.
Annual Senior Manager/Attorney Salary Structure Review - The salary structure
levels for senior managers and attorneys are evaluated on an annual basis. The review
is performed using salary survey data and factors in wage compression concerns related
to movement of the employee wage structure. Recommended increases to structure are
reviewed by executive leadership and the revised structures are used for senior
manager/attorney compensation changes which occurs in February of each year (with a
retroactive effective date to the beginning of the year). While the GWA is applied to all
eligible employee wages, the percent for the senior manager and attorney structure
movement is not applied uniformly to senior manager/attorney compensation. Individual
senior manager and attorney increases are determined based on budget, performance,
internal equity, and placement within the salary structure.
The response to this Request is sponsored by Sarah Griffin, VP Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 36
REQUEST FOR PRODUCTION NO. 31: Please provide a copy of the Company's
credit card, or purchase card, policy.
RESPONSE TO REQUEST FOR PRODUCTION NO. 31: Please see “Attachment
- Response to Staff Request No. 31”.
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 - 37
REQUEST FOR PRODUCTION NO. 32: Please provide statements for any
Company credit cards that include spending during 2022 through 2023 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 32: Please see
“Confidential Attachment 1 - Response to Staff Request No. 32 - 2022” and “Confidential
Attachment 2 – Response to Staff Request No. 32 – 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 - 38
REQUEST FOR PRODUCTION NO. 34: Please describe the Company's method
for developing, managing, executing, and completing Capital Projects in a least cost
manner. Please provide a copy of Company's policies and procedures documenting the
process.
RESPONSE TO REQUEST FOR PRODUCTION NO. 34: Idaho Power utilizes an
annual capital budget process. Capital budgets are generally project based. Managers
submit capital project proposals for senior management review. The capital projects are
reviewed and approved by the executive management team. The capital budget is then
reviewed and approved by the Idaho Power Board of Directors. Because Idaho Power
has an obligation to serve and most projects are required to maintain reliability or serve
load, there is not one standard way the Company evaluates each project. Individual facts
and circumstances determine how projects are executed in a prudent manner.
Additionally, Idaho Power has a Procurement Policy and a Procurement Standard in place
to provide guidance for procurement activities including competitive bidding practices and
to help ensure that procurement decisions are made based on the best overall value to
Idaho Power and its customers.
A copy of Idaho Power’s Procurement Policy is attached as Attachment 1-
Response to Staff Request No. 34. A copy of Idaho Power’s Procurement Standard is
attached as Attachment 2-Response to Staff Request No. 34. Idaho Power monitors its
capital budget monthly through variance analysis reporting and quarterly through budget
update analysis and reporting. Please see Idaho Power’s Response to Staff Request No.
37 for copies of Idaho Power’s variance reports for 2018 through May 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 39
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 - 40
REQUEST FOR PRODUCTION NO. 35: Please provide an Excel file with formulas
intact and enabled showing all capital projects completed, by year, from 2012 through
2023 to date. For each project, please include the following: name or title, number or
identifier, in-service date, cost-of service classification, description, rationale analysis or
business need, target start date, actual start date, target completion date, actual
completion date, estimated cost, budgeted cost, actual cost, if a cost benefit analysis was
performed, if the work was primarily completed by employees or contractors, and if a
request-for-proposal was performed.
RESPONSE TO REQUEST FOR PRODUCTION NO. 35: Please see Confidential
Attachment 1-Response to Staff Request No. 35 containing all readily available requested
information for the approximately 115,000 capital projects completed over the requested
time period. This includes Work Order Number, Work Order Description, Budget ID, In-
service Date, Amount, Actual Start Date, and Business Need on the first tab of Attachment
1 labeled ‘Work Orders’. On the second tab of Attachment 1 labeled ‘Budget’ Idaho Power
has provided actual and budget amounts for all budget IDs that had a work order listed
on the first tab of Attachment 1. It should be noted that a budget ID can have multiple
work orders. Some projects are not budgeted, such as individual road widening projects
and individual emergency reconstruction projects. The list of completed projects excludes
Boardman, Bridger and Valmy power plant projects because those projects were
evaluated as part of each of their respective regulatory filings.
For class cost-of-service classification of the completed projects, fixed plant has
been classified as either demand or customer for the respective functionalized cost as
described in the Class Cost-of-Service Process Guide exhibit to Company Witness Pawel

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 41
Goralski’s testimony.1
For additional project-specific information not included in the attached file, Idaho
Power requests that Staff identify a sample for which Idaho Power will manually gather
the requested information.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

1 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, Goralski DI, Exhibit No. 36.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 42
REQUEST FOR PRODUCTION NO. 36: Please provide a detailed Excel file of the
2023 capital expenditure budget including name or title, number or identifier, in-service
date, cost-of-service classification, description, rationale analysis or business need,
target start date, actual start date (if started prior to 2023), target completion date, actual
completion date (if completed in 2023), estimated cost, budgeted cost, actual cost, if a
cost benefit analysis was performed, if the work was primarily completed by employees
or contractors, and if a request-for-proposal was performed.
RESPONSE TO REQUEST FOR PRODUCTION NO. 36: Please see Confidential
Attachment 1-Response to Staff Request No. 36 containing all readily available requested
information for the approximately 800 2023 budgeted capital projects. This includes
Budget ID, Name/Title, Projected In-service Date, Description, Business Need,
Estimated/Budgeted Cost, Actual Project Start Date, Actual In-service Date and Actual
Cost (2023 through May). For class cost-of-service classification of the 2023 capital
expenditure budget, fixed plant has been classified as either demand or customer for the
respective functionalized cost as described in the Class Cost-of-Service Process Guide
exhibit to Company Witness Pawel Goralski’s testimony.2
For additional project-specific information not included in the attached file, Idaho
Power requests that Staff identify a sample for which Idaho Power will manually gather
the requested information.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

2 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, Goralski DI, Exhibit No. 36.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 43
DATED at Boise, Idaho, this 5th day of July 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 - 44

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 5th day of July 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

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

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

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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 45

Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 46

City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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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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Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702

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Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

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Stacy Gust, Regulatory Administrative
Assistant