20230718IPC to Staff 38-80.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

July 18, 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 the
Second 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 18, 2023 4:27PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
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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CASE NO. IPC-E-23-11

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Second Production Request of the Commission Staff (“Commission” or
“Staff”) dated June 27, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 38: Please identify how many Customer
Service Representatives ("CSRs") are employed by the Company.
RESPONSE TO REQUEST FOR PRODUCTION NO. 38: As of June 2023, the
Company employed 59 CSRs within its Customer Service Center to handle incoming
customer calls.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 39: Please list how many CSRs work in the
Customer Service Center and how many work remote.
RESPONSE TO REQUEST FOR PRODUCTION NO. 39: Of the 59 CSRs working
in the Company’s Customer Service Center, none work entirely remotely. However, CSRs
who meet the necessary at-home technology requirements, and who have also
completed all necessary customer service-related trainings, are eligible to work a hybrid
schedule in which they work from home on Mondays and Fridays, and work in the office
Tuesdays through Thursdays (“Hybrid Schedule”). As of June 2023, approximately 42
CSRs are working under the Hybrid Schedule.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 40: Please list the operating hours of the
Customer Service Center.
RESPONSE TO REQUEST FOR PRODUCTION NO. 40: The Customer Service
Center’s operating hours, excluding holidays observed by the Company, are Monday
through Friday from 7:30 a.m. to 6:30 p.m., Mountain Standard Time.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 41: Please describe the top menu self-help
options that are available to customers using the Company's Interactive Voice Response
system. Please provide the utilization rate for each available option for the past three
years (2020, 2021, and 2022).
RESPONSE TO REQUEST FOR PRODUCTION NO. 41: Please see the
attachment provided in response to this request. As part of this response, the Company
has provided the count of the most frequently utilized self-serve options within the
Company’s Interactive Voice Response system (“IVR”). Any difference between the total
count of IVR contained calls and the sum of the most frequently utilized self-serve options
is due to lesser utilized self-serve options not being tracked, as well as hang ups occurring
within the IVR being considered as “IVR contained calls.”
A description of each of the various IVR-related line items within the provided
attachment is below.
 IVR Calls Offered: the count of calls placed to an Idaho Power number that
directs to the IVR. The primary Idaho Power numbers directing to the IVR are:
[phone], [phone], 1-800-488-6151, and 1-800-488-6150.
 IVR Calls Transferred to Call Center Agents: the count of calls that were
directed to the IVR and subsequently transferred out to an agent in the Customer
Service Center. The reason that a transfer to an agent may occur includes, but is
not limited to, the customer selecting to speak with an agent or the customer
being ineligible or not having the necessary information to perform the selected
type of self-serve transaction.
 IVR Contained Calls: the count of calls that were directed to and completed
within the IVR. The type of calls included within this count are those when
customers’ transactions are completed entirely within the IVR, when a hang up
occurs while in the IVR (which may happen due to cell signal loss, distractions
while calling, customers being asked for authentication information that they
might not have on hand, etc.), or when a “robo dialer” calls an Idaho Power
number associated with the IVR.
 Percent of IVR Contained Calls: the total amount of “IVR Contained Calls”
compared to the total amount of “IVR Calls Offered.”

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 42: Please provide the Company's
performance objectives for handling incoming calls.
RESPONSE TO REQUEST FOR PRODUCTION NO. 42: Please see the below
performance objectives used by the Company when evaluating CSRs’ effectiveness in
handling inbound customer calls.
 Average Handle Time (“AHT”): the average amount of time that it takes a CSR
to speak with a customer, assist with their question(s), and record any relevant
interaction record(s). Different AHT performance thresholds are used for the
various inbound call queues in recognition that certain inbound call queues may
inherently require additional handling time due to the potential complexity of
questions that customers in these call queues could ask. As shown in the table
below, CSRs’ AHT performance is rated as “Does Not Meet,” “Meets,” or
“Exceeds” for each respective inbound call queue based on the queue’s
associated upper and lower AHT thresholds. A CSR is considered to meet the
Company’s AHT performance objective if their AHT is between the applicable
inbound call queue’s upper and lower AHT threshold amounts.
 Accuracy: the number of errors that a CSR makes per 1,000 interactions per
month. As shown in the table below, CSRs’ accuracy performance is rated as
“Does Not Meet,” “Meets,” or “Exceeds.” A CSR is considered to meet the
Company’s Accuracy performance objective if their number of monthly errors is
between the upper and lower threshold amounts.
 Interaction Quality Management (“IQM”): the effectiveness rating of a CSR in
communicating with customers. As shown in the table below, CSRs’ IQM is rated

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
as “Does Not Meet,” “Meets,” or “Exceeds.” A CSR is considered to meet the
Company’s IQM performance objective if their communication effectiveness rating
is between the upper and lower threshold amounts.
Idaho Power’s Performance Objectives for Inbound Customer Calls:
Average Handle Time Measure
Inbound Call Queue
Does Not Meet
( > seconds) Meets
Exceeds
(< seconds)
Billing 463 368
Commercial & Irrigation 546 437
Credit and Collections 432 343
Lines/New Construction 496 395
Move In Move Out 462 367
Spanish 466 371
Accuracy Measure
Does Not Meet Meets Exceeds
Errors/1000 interactions > 10 per month <= 5 per month
Quality Measure
Does Not Meet Meets Exceeds
Interaction Quality
Management < 85% >= 94%

The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 43: What steps does the Company take if it
fails to meet its performance objectives?
RESPONSE TO REQUEST FOR PRODUCTION NO. 43: In respect to the
Company failing to meet its performance objectives when handling inbound customer
calls, the Company’s Customer Service leadership team seeks to identify the
performance failure’s root cause and implement actions aimed at improving future overall
results. Such actions that may be implemented include, but are not limited to, enhanced
trainings for CSRs, a holistic review of processes and procedures to identify opportunities
for increased efficiency, and leveraging forward hiring practices.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 44: Please provide the service level1 for the
Customer Service Center by month for each of the past three years (2020, 2021, and
2022).
RESPONSE TO REQUEST FOR PRODUCTION NO. 44: Please see the table
below, which details the monthly service level of the Company’s Customer Service Center
between 2020 and 2022. The provided monthly service level percentages reflect the
percentage of calls answered within 60 seconds.
Service Level
Month 2020 2021 2022
Jan. 76.6% 45.4% 35.7%
Feb. 81.3% 60.2% 40.2%
Mar. 77.4% 48.5% 17.6%
Apr. 87.3% 70.4% 54.1%
May 79.6% 71.9% 53.0%
Jun. 69.2% 61.7% 88.6%
Jul. 67.4% 25.7% 78.6%
Aug. 48.1% 28.5% 88.0%
Sep. 40.7% 33.6% 75.6%
Oct. 68.4% 40.7% 90.5%
Nov. 57.9% 60.1% 93.0%
Dec. 47.1% 63.3% 96.5%
Year 67.8% 50.6% 68.2%

The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

1 "Service level" is the percentage of calls answered within a certain number of seconds, e.g., 80% of calls answered
within 20 seconds.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
REQUEST FOR PRODUCTION NO. 45: Please provide the number of incoming
calls handled by the Customer Service Center by month for each of the past three years
(2020, 2021, and 2022).
RESPONSE TO REQUEST FOR PRODUCTION NO. 45: Please see the table
below, which details the number of monthly incoming calls between 2020 and 2022 that
were handled by the Company’s Customer Service Center.
Incoming Calls
Month 2020 2021 2022
Jan. 50,075 41,476 44,341
Feb. 45,964 41,243 43,259
Mar. 56,612 52,416 49,916
Apr. 48,931 49,259 49,453
May 43,344 52,539 49,257
Jun. 48,321 61,331 50,305
Jul. 48,901 47,152 50,490
Aug. 56,419 50,092 59,493
Sep. 56,305 50,048 52,660
Oct. 53,250 49,272 50,880
Nov. 45,653 46,406 46,966
Dec. 47,133 49,925 42,741
Year 600,908 591,159 589,761

The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
REQUEST FOR PRODUCTION NO. 46: Please provide the number of abandoned
calls2 to the Customer Service Center by month for each of the past three years (2020,
2021 and 2022).
RESPONSE TO REQUEST FOR PRODUCTION NO. 46: Please see the table
below, which details the number of monthly calls received between 2020 and 2022 that
were routed to the Company’s Customer Service Center but subsequently abandoned
prior to being connected with an agent.
Abandoned Calls
Month 2020 2021 2022
Jan. 1,900 6,763 14,204
Feb. 1,516 3,013 9,015
Mar. 2,280 7,258 18,506
Apr. 1,864 3,377 5,778
May 2,636 4,449 5,494
Jun. 3,194 4,395 1,714
Jul. 3,315 14,429 1,933
Aug. 4,964 14,968 1,908
Sep. 10,000 10,061 3,115
Oct. 3,366 8,266 1,198
Nov. 4,563 4,044 1,355
Dec. 6,342 3,894 894
Year 45,940 84,917 65,114

The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

2 "Abandoned calls" are calls that reach the Company's incoming telephone system, but the calling party terminates
the call before speaking with a CSR.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
REQUEST FOR PRODUCTION NO. 47: Please provide the average speed of
answer3 for the Customer Service Center by month for each of the past three years (2020,
2021, and 2022).
RESPONSE TO REQUEST FOR PRODUCTION NO. 47: Please see the table
below, which details the Company’s Customer Service Center’s monthly average speed
of answer for calls received between 2020 and 2022.

Average Speed of Answer
(in seconds)
Month 2020 2021 2022
Jan. 50 217 383
Feb. 41 95 259
Mar. 78 174 465
Apr. 42 88 135
May 60 77 149
Jun. 82 76 34
Jul. 99 367 51
Aug. 144 361 33
Sep. 226 253 65
Oct. 87 228 27
Nov. 125 126 24
Dec. 192 116 19
Year 102 182 137

The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

3 "Average speed of answer" is the interval (typically measured in seconds) between when a call reaches the
Company's incoming telephone system and when the call is picked up by a customer service representative.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
REQUEST FOR PRODUCTION NO. 48: Please provide the average handling
time4 for the Customer Service Center by month for each of the past three years (2020,
2021, and 2022).
RESPONSE TO REQUEST FOR PRODUCTION NO. 48: Please see the table
below, which details the Company’s Customer Service Center’s monthly average
handling time, including all respective “off-line” work, for calls received between 2020 and
2022.

Average Handling Time
(in seconds)
Month 2020 2021 2022
Jan. 350 439 428
Feb. 347 419 445
Mar. 351 414 458
Apr. 362 417 427
May 369 389 389
Jun. 388 388 363
Jul. 397 410 364
Aug. 421 428 364
Sep. 417 419 365
Oct. 403 417 360
Nov. 393 413 351
Dec. 405 396 344
Year 384 412 388

The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

4 "Average handling time" is the average amount of time (usually expressed in minutes) it takes for a CSR to talk
with a customer plus any additional "off-line" time it takes to complete the transaction or fully resolve the
customer's issue(s).

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
REQUEST FOR PRODUCTION NO. 49: Please provide the first call resolution
rate5 for the Customer Service Center by month for each of the past three years (2020,
2021, and 2022).
RESPONSE TO REQUEST FOR PRODUCTION NO. 49: Please see the table
below, which details the Company’s Customer Service Center’s monthly first call
resolution rate for all calls received between 2020 and 2022. The Company’s “first call
resolution rate” excludes outage-related calls and is defined as the percentage of phone
numbers that do not place more than one call to the Company’s Customer Service Center
within a 72-hour period.
First Call Resolution Rate
Month 2020 2021 2022
Jan 63.3% 61.7% 57.7%
Feb 65.7% 61.2% 63.2%
Mar 64.6% 63.7% 63.4%
Apr 61.9% 63.9% 63.1%
May 54.3% 62.9% 61.6%
Jun 59.3% 58.5% 62.2%
Jul 59.8% 62.8% 64.2%
Aug 57.5% 61.9% 63.0%
Sep 39.0% 62.4% 63.8%
Oct 62.4% 62.4% 62.2%
Nov 61.3% 62.5% 64.0%
Dec 62.3% 62.6% 63.7%
Year 57.8% 62.1% 62.6%

The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

5 "First call resolution rate" is the percentage of calls where the transaction, inquiry, or complaint is resolved upon
initial contact with the Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
REQUEST FOR PRODUCTION NO. 50: Please provide the average response
time6 for email transactions for the Customer Service Center by month for each of the
past three years (2020, 2021, and 2022).
RESPONSE TO REQUEST FOR PRODUCTION NO. 50: Please see the table
below, which details the Company’s Customer Service Center’s average monthly
response time for email transactions received between 2020 and 2022. Of note, the
average response times provided below encompass the entire duration from the moment
an email is received, including times outside of the Customer Service Center’s operating
hours.

Average Email Response Time
(in hours:minutes:seconds)
Month 2020 2021 2022
Jan 2:53:28 9:14:41 56:37:01
Feb 2:44:33 3:48:03 50:08:03
Mar 3:19:54 4:38:51 55:45:19
Apr 2:08:11 6:12:10 11:15:45
May 3:10:24 3:42:30 16:00:01
Jun 4:57:10 9:23:43 5:36:19
Jul 5:47:56 29:00:01 11:04:58
Aug 4:26:53 24:37:45 9:30:56
Sep 8:17:34 14:31:43 9:52:54
Oct 3:35:24 18:49:05 12:34:12
Nov 7:13:50 15:30:31 17:13:18
Dec 8:53:22 20:29:47 4:28:22
Year 4:47:23 13:19:54 21:40:36

The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

6 "Average response time" is the average number of hours from receipt of an e-mail by the Company to sending a
substantive response; auto-response acknowledgements do not count as a substantive response.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
REQUEST FOR PRODUCTION NO. 51: Please explain the efforts put forth by the
Company to promote Project Share.
RESPONSE TO REQUEST FOR PRODUCTION NO. 51: The Company uses a
variety of methods to promote Project Share, all of which aim to encourage customer
participation and donations. Below are examples of the efforts put forth by the Company
to promote Project Share.
1. Project Share Bill Messages, Inserts, and Marketing: Bill messages are
frequently included on the monthly bills of all residential customers not currently
donating to Project Share in order to raise awareness of the program and
encourage new participation and donations. Additionally, the Company includes
an annual bill insert during the winter season to promote Project Share to
residential customers, as well as including a Project Share-related advertisement
at the bottom of each month’s bill.
2. Flyers: The Company produces flyers promoting the availability of bill assistance
through Project Share, the contact information for outreach offices, and how
customers can donate to the program. These flyers are left for attendees’
reference as part of the Company’s energy efficiency presentations at schools,
senior centers, and other community events.
3. Idaho Power’s Website: The Company’s website describes Project Share, how
the program works, and provides customers with the ability to electronically sign
up and pledge a donation.
4. Connections Articles: Connections articles are an educational publication
produced by Idaho Power and circulated in customers’ monthly electric bills.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
Connections articles focusing on Project Share are issued annually each
Fall/Winter.
5. News Briefs: The Company releases weekly News Briefs for the media to pick
up for their publications. A News Brief discussing Project Share and encouraging
customer donations to the program is typically issued in January of each year.
6. Phone Engagement: The Company’s CSRs, Customer Solutions Advisors, and
Support & Outage Specialists promote Project Share with customers who call the
Company and express an inability to pay their bill. In addition, a message
promoting Project Share was played on the IVR system from December of 2022
through March of 2023 during caller hold-times. This Project Share-related
message was aimed toward raising customer awareness and participation in the
program.
7. In-Person Engagement. The Company’s Energy Advisors and Program
Specialists promote Project Share through direct interaction with the public, such
as when staffing a booth at the Idaho Department of Health and Welfare’s Annual
Resource Fair or during one-on-one interactions with customers.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19
REQUEST FOR PRODUCTION NO. 52: Please describe the types of advertising
(radio, tv, bill insert, welcome kit, etc.) conducted in Idaho to inform and educate
customers about the following:
a. Energy assistance and bill payment options; and
b. Winter Moratorium and the Winter Payment Plan.
In addition, please provide copies of any written brochures or documents sent or
otherwise provided to customers for each defined category listed in this question.
RESPONSE TO REQUEST FOR PRODUCTION NO. 52:
a. For energy assistance, the Company routinely informs customers of bill
payment options and assistance (including Project Share) through the following
tactics, examples of which are included as Attachment 1 to this request:
1. Brochures
2. Flyers
3. Postcards
4. Bill inserts
5. News briefs
6. IVR messaging
7. Social media posts
8. The Company’s website
9. Connections articles
10. Digital ads
11. My Account

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 20
b. For Winter Moratorium and the Winter Payment Plan, the Company includes
an insert describing the terms and/or availability of these offerings with all
reminder and disconnect notices sent to residential customers during the
months of November through February of each year. Additionally, the Company
notifies all residential customers of the availability of winter-related protections
when providing an annual summary of the Commission’s Utility Customer
Relations Rules, pursuant to IDAPA 31.21.01.700.02.a. This information is also
available on the Company’s website year-round. Examples of each of these
communications can be found within Attachment 2 to this response.
The response to this request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 21
REQUEST FOR PRODUCTION NO. 53: Please describe in detail the type of
standard payment plans/arrangements the Company offers its customers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 53: The type of standard
payment plans/arrangements that the Company offers its small commercial and/or
residential customers are as follows:
 Promise to Pay: a customer’s full outstanding balance is due within 10 days from
the date the plan is entered into.
 Standard Time Pay: one-half of a customer’s outstanding balance is due within
10 days from the date the plan is entered into, and the remaining half of their
outstanding balance is due within 30 days from the date the plan is entered into.
 Equal Pay: residential customers can elect to equalize and paydown their
outstanding balance over 3-, 4-, or 7-month timeframes. Equal Pay arrangements
require that a residential customer’s first installment amount be paid within 10 days
from the date the arrangement is entered into, and all remaining installment
amounts are due every 30 days thereafter. Equal Pay installment amounts, which
only paydown a residential customer’s arrears, are in addition to a residential
customer’s current monthly bill.
 Level Pay: customers may request to levelize their outstanding balance and
average monthly bill over a 12-month period. Level Pay arrangements require that
a customer’s first installment amount be paid within 10 days from the date this
arrangement is entered into, and their remaining 11 installment payments are due
every 30 days thereafter.
 Winter Payment Plan: a payment arrangement that is equal to half of a residential
customer’s normal Level Pay amount. The Winter Payment Plan is only offered to
residential customers between November through February of each year, and the
first installment amount is due within 10 days from the date the arrangement is
entered into. Residential customers electing this plan are responsible for paying or
making other arrangements for any remaining balance owed following the plan’s
termination.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 22
REQUEST FOR PRODUCTION NO. 54: Please describe in detail the temporary
alternative/modified payment/plan arrangements the Company offered its customers in
2020 and 2021 due to COVID-19.
RESPONSE TO REQUEST FOR PRODUCTION NO. 54: Prior to COVID-19, the
Company did not offer an Equal Pay arrangement option to its residential customers in
Idaho. However, in order to expand the type of payment arrangement options available
to residential customers seeking to paydown their arrears during the pandemic, the
Company began offering 3-, 4-, and 7-month Equal Pay arrangements in 2020.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 23
REQUEST FOR PRODUCTION NO. 55: Did the Company make any of the
temporary alternative/modified payment plan/arrangements a permanent offering?
Explain. If no, please also explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 55: Yes, the Company
continues to offer its residential customers the option of enrolling in a 3-, 4-, or 7-month
Equal Pay arrangement.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 24
REQUEST FOR PRODUCTION NO. 56: For each of the past three winters (2020-
2021, 2021-2022, and 2022-2023), how many participants were under Winter Moratorium
each year? Of that amount, how many participants agreed to be placed on the winter
payment plan and how many were unable to meet their monthly payment?
RESPONSE TO REQUEST FOR PRODUCTION NO. 56: Please see the table
below, which details the number of participants under Winter Moratorium each year, the
number of participants who were placed on a Winter Payment Plan, and the number of
participants unable to meet their monthly payment. Notably, not all Winter Moratorium
participants request to be placed on a Winter Payment Plan.
Winter Moratorium Year
Category 2020-2021 2021-2022 2022-2023
Customers Under Winter
Moratorium 11,068 11,344 12,389
Winter Payment Plan participants 5,262 6,503 7,603
Customers Unable to Meet Their
Monthly Payment 4,304 4,913 5,065

The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 25
REQUEST FOR PRODUCTION NO. 57: When a request is made for both new
service and disconnection of service, does the Company issue the requester a
confirmation number? If no, please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 57: No. If a customer
requests receipt of a confirmation number, a CSR will provide the customer with their
account number and make a note of the transaction within the account’s interaction
record. Customers requesting to start, stop, or move service using the Company’s online
platform receive an email confirmation noting the details of their request (the address
where the request is to be performed, the start or stop date for electric service, etc.).
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 26
REQUEST FOR PRODUCTION NO. 58: When a request is made to either add or
remove a name to an existing account, does the Company issue the requester a
confirmation number? If no, please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 58: No. The Company does
not have an automated or systematic way to issue a confirmation number to customers
when they request to add or remove a name on an existing account.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 27
REQUEST FOR PRODUCTION NO. 59: In situations when a payment
arrangement is setup and the required payment is paid late or underpaid, why does the
Company terminate the payment arrangement and proceed with disconnection of service
rather than keeping the arrangement in place if the customer continues to make payments
to pay off the arrearage?
RESPONSE TO REQUEST FOR PRODUCTION NO. 59: The Company’s credit
and collections practices are designed to be compliant with the Commission’s Utility
Customer Relations Rules. Accordingly, IDAPA 31.21.01.302.01.c allows for the
termination of service, after adequate notice has been provided, if a customer fails to
abide by the terms of their payment arrangement.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 28
REQUEST FOR PRODUCTION NO. 60: Please provide the Company's actual
insurance expenses for Wildfire for each year for 2020-2023. Please provide supporting
documentation of actual expenses, including workpapers, and any documentation of
expected increased expenses (i.e., emails, invoices, memos) for 2019 through 2024.
RESPONSE TO REQUEST FOR PRODUCTION NO. 60: The Company’s
insurance expenses for 2020 through May 2023 are provided in Confidential Attachment
1 to this response. Invoices for the 2019 through May 2023 are provided in Confidential
Attachments 2 to 6 to this response. Insurance costs for 2024 are unknown at this time.
Insurance markets continue to be volatile and, as a result, premium increases are difficult
to forecast with any reasonable confidence.
The response to this Request is sponsored by Brian Buckham, SVP & Chief
Financial Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 29
REQUEST FOR PRODUCTION NO. 61: Please clarify that the adjustment to the
wildfire deferral balance of $14,022,056 is the vegetation management expenses that are
excluded in the Company's request for amortization. Also, please clarify that the balance
of the wildfire deferral of $13,056,171 is what is being sought in amortization over seven
years.
RESPONSE TO REQUEST FOR PRODUCTION NO. 61: The adjustment to the
December 31, 2022, wildfire deferral balance of $14,022,056 is the vegetation
management expenses that the Company is not requesting amortization for at this time.
The remaining balance of $13,056,171 is what is being requested to amortize over seven
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 SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 30
REQUEST FOR PRODUCTION NO. 62: In the Case No. IPC-E-21-02, the
Company was authorized to defer incremental Operational and Maintenance ("O&M")
expenses for wildfire mitigation above 2019 actual costs escalated annually for inflation
(1.81% in 2019). Please provide the current baseline from which the Company begins
deferring incremental O&M expenses.
RESPONSE TO REQUEST FOR PRODUCTION NO. 62: As a point of
clarification, Idaho Power’s initial wildfire mitigation deferral request proposed to establish
2019 baseline levels for insurance and vegetation management O&M expenses—other
categories/types of wildfire mitigation were new to the Company as of the first deferral
and, therefore, did not have a 2019 baseline level.
With respect to inflation, the Company proposed that insurance expenses over the
2019 base would not be adjusted for inflation (due to the volatile and unpredictable nature
of the insurance market)7 but that vegetation management expenses above 2019 levels
would be escalated annually for inflation at 1.81 percent.8
The Commission’s Order in the first deferral authorizes the Company to defer all
wildfire mitigation expenses and specifically authorizes the ability to defer O&M costs over
2019 baseline levels for vegetation management and insurance.9 The Order, however,
only generally notes the Company’s proposal to adjust O&M for 2019 baseline levels for
inflation; it is not specific about the Company’s proposed treatment of insurance.10

7 In the Matter of the Application of Idaho Power Company for an Accounting Order Authorizing the Deferral of
Incremental Wildfire Mitigation and Insurance Costs, IPC-E-21-02 at 27-28.
8 Id. at 24.
9 Order No. 35077 at 3.
10 Id., Footnote 4.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 31
Considering the Commission’s reference to the Company’s proposal, Idaho Power has
proceeded with cost tracking as detailed in its Application.
To this end, the insurance baseline for 2019 expense is $7,566,208. The baseline
for vegetation management is escalated at 1.81 percent annually over 2019 actual
expenses, resulting in the current (2023) baseline for vegetation management of
$11,539,506.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 32
REQUEST FOR PRODUCTION NO. 63: Please provide an Excel worksheet that
details the actual costs for 2020 to date, by year, separated into the various components
of the Wildfire Mitigation Plan ("WMP") as listed in Table 6 of the WMP. WMP at 35.
Please quantify the incremental amounts that have been deferred by component.
RESPONSE TO REQUEST FOR PRODUCTION NO. 63: The Company began
tracking WMP costs in 2021, consistent with the timing of the Company’s first wildfire
deferral, which was filed on January 22, 2021.11 Confidential Attachment – Response to
Staff Request No. 63 shows actual costs from 2021-2023 year-to-date May.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

11 In the Matter of the Application of Idaho Power Company for an Accounting Order Authorizing the Deferral of
Incremental Wildfire Mitigation and Insurance Costs, IPC-E-21-02.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 33
REQUEST FOR PRODUCTION NO. 64: Please provide a worksheet that details
a list of all O&M expenses incurred for the WMP for 2020 to date. In your response, please
provide vendor name, amount, date, FERC account number, and a brief description of
the expense.
RESPONSE TO REQUEST FOR PRODUCTION NO. 64: The Company began
tracking WMP costs in 2021. Confidential Attachment – Response to Staff Request No.
64 shows costs from 2021-2023 Year-to-date May.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 34
REQUEST FOR PRODUCTION NO. 65: In Final Order No. 35717, the Company
was ordered to develop project criteria, a selection process, and cost-benefit analysis for
completed and future undergrounding distribution line projects related to the wildfire
mitigation prior to the Company's next general rate case. Please provide the following
information:
a. An update to the status of the development of project criteria, selection process,
and cost benefit analysis;
b. If these are developed, please provide supporting documentation of each of them;
and
c. If these haven't been developed, please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO. 65: Idaho Power details the
criteria used for selecting underground conversion project locations in Colburn Direct,
page 63. The criteria include evaluating wildfire risk modeling scores, fire history, risk
drivers, Public Safety Power Shutoff (“PSPS”) impacts to customers, geographic
characteristics, and other attributes that increase wildfire risk or present patrol and
restoration challenges. Each project under consideration for underground conversion is
evaluated based on those criteria along with conversion costs and associated benefits.
In addition to the above criteria, the Company is developing a Risk-Spend Efficiency
(“RSE”) model to measure the risk-reduction benefit and costs of different mitigation
activities. The RSE model is an additional data point that will help inform wildfire
mitigation-related decision making and provide a framework for selecting cost-effective
mitigation measures. Although still under development, the RSE model will provide a
numerical score that represents changes in risk per dollar spent on mitigation and help
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 35
determine the cost effectiveness of underground conversion projects versus other
mitigation activities or programs. The Company has engaged with other utilities and
industry partners on the steps needed to complete and implement an RSE model. The
work is expected to take up to one year to complete due to the complexities of building a
model that quantifies risk reduction for the various mitigation activities occurring in
different geographic areas, terrain, line configurations, and asset types and conditions.
The Company will provide a summary of progress made on developing an RSE
model during the pre-fire season meeting with Staff for the 2024 wildfire season.
The response to this Request is sponsored by Mitch Colburn, Vice President,
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 36
REQUEST FOR PRODUCTION NO. 66: Please describe any occurrences where
the Company undergrounded any distribution lines both inside and outside of the scope
of the WMP. If any, please provide a supporting worksheet detailing the cost, date in
service, and location (within or outside a Red Risk Zone).
RESPONSE TO REQUEST FOR PRODUCTION NO. 66: In consultation with
Staff, Idaho Power Company has requested an extension for this response and will deliver
it as soon as possible.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 37
REQUEST FOR PRODUCTION NO. 67: Please provide all funding alternatives
and sources that the Company has pursued and/or received for its WMP. Please provide
supporting workpapers. If any, please explain how that is displayed within the WMP and
incorporated in the Company's filing.
RESPONSE TO REQUEST FOR PRODUCTION NO. 67: Idaho Power is actively
reviewing and seeking grants in support of infrastructure, resiliency, and wildfire
mitigation. In late 2022, the Company applied for and was awarded two grants from the
Idaho Office of Energy and Mineral Resources that focus on wildfire mitigation and
improving the resiliency of the transmission system. The awarded grants are summarized
below:
 One grant provided $250,000 to add a fire-protective mesh to transmission poles
in wildfire prone areas located throughout Idaho. This project improves resiliency
of wood poles and improves reliability for customers during wildfire events by
preventing poles from burning down, see Idaho Power’s 2023 Wildfire Mitigation
Plan, page 40. Rebuilding costs are minimized with this solution and communities
can return to normal functions safely and more quickly after a wildfire event. The
application for this grant is provided as Attachment 1 – Response to Staff Request
No. 67.
 One grant provided funding of $150,000 to pilot satellite imagery and vegetation
artificial intelligence modeling using Idaho locations. This grant expanded the pilot
detailed the WMP which was focused on using satellites and aerial imagery to
detect vegetation ignition risk. With this grant, Idaho Power trialed technologies to
determine how viable artificial intelligence is at assessing vegetation

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 38
encroachments and dead or dying trees within striking distance of our distribution
and transmission lines, see Idaho Power’s 2023 WMP, page 42. The grant
application is provided as Attachment 2 – Response to Staff’s Request No. 67.
Because the Company was awarded these grants in late 2022, neither grant was
specifically noted in the 2023 WMP. The Company will include this information in the 2024
WMP.
The work associated with both grants was performed in 2022. For the mesh wrap
grant, the work was tracked in a work order outside of the WMP and, as a result, was not
included in the wildfire deferral in 2022. Additionally, the mesh wrap grant funding was
not received until 2023, therefore the grant amount was not deducted from 2022
expenditures. Similarly, the satellite imagery grant amount was not included in the 2022
deferral, and the funds have yet to be received. Therefore, the satellite imagery grant
funding was not deducted from 2022 expenditures.
The response to this Request is sponsored by Mitch Colburn, Vice President,
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 39
REQUEST FOR PRODUCTION NO. 68: The initial results of the satellite pilot
project in the WMP "...did not demonstrate sufficient accuracy needed to make risk
informed decisions for vegetation encroachment." Colburn Direct at 53. Additionally
stated, "[t]he Company plans to reassess the technology in 3 to 5 years as improvements
in machine learning and AI are made." Colburn Direct at 53. Please answer the following:
a. Please explain if the Company will discontinue the pilot project based on these
results; and
b. If so, please explain the impact this will have on expected expenses for the test
year ending December 31, 2023.
RESPONSE TO REQUEST FOR PRODUCTION NO. 68: While the initial results
of the satellite and aerial imagery pilot did not produce the desired outcome (i.e., the
accuracy of the imagery was not sufficient to offset any amount of on-the-ground
vegetation management work), it provided valuable insights about the trialed
technologies. The Company continues to believe that the technology has the potential to
dramatically change the way the Company performs vegetation management work and
patrols and, in turn, benefit customers through lower annual vegetation management
costs.
With this potential outcome in mind, the Company finds merit in continuing the pilot
in 2023 and has been working with the vendors to further refine machine learning and
artificial intelligence algorithms used for the surveys conducted in 2022. This new work is
focused on improving numerical methods and accuracy in areas where the 2022 surveys
failed to provide desired results due to topography or conductor sizing and/or material.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 40
The response to this Request is sponsored by Mitch Colburn, Vice President,
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 41
REQUEST FOR PRODUCTION NO. 69: Please explain why the Company used
additional personnel to "evaluate the annual use of thermography inspections in Red Risk
Zones..." Colburn at 44. Also, please explain any benefits the expanded use of
thermography inspections gained compared to the historical approach of periodic use
across its system.
RESPONSE TO REQUEST FOR PRODUCTION NO. 69: The Company uses
additional personnel to complete annual infrared thermography inspections in Red Risk
Zones. The above-referenced language in the Direct Testimony of Mitch Colburn at 44
may have been confusing, as the work of the additional personnel is two-fold: they
evaluate the use of thermography inspections and also conduct the inspections. This work
included approximately 3,800 inspections in 2022 and is an annual component of work
identified in the WMP.
Thermography inspections are detailed and require time to perform the on-site
inspection and analyze images using thermography software post inspection. Therefore,
a dedicated resource is needed to complete the targeted number of inspections each
year. Performing more frequent thermography inspections provides a greater likelihood
of detecting overheating or failed equipment, connections, splices, and/or conductor.
Another benefit of performing the inspections is that the inspector provides an additional
set of eyes on assets in Red Risk Zones while on site. While Idaho Power has historically
performed periodic infrared inspections, they were mainly performed for reliability and
maintenance purposes. The expanded use on an annual basis has resulted in the
identification of several defects that would have gone unnoticed based on the previous
periodic cycle.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 42
The response to this Request is sponsored by Mitch Colburn, Vice President,
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 43
REQUEST FOR PRODUCTION NO. 70: Please provide a worksheet that
describes any participation in wildfire-related groups. Please include the name of the
group, description of the group, cost of participation, and quantify the tangible and
intangible benefits gained from participation in each group.
RESPONSE TO REQUEST FOR PRODUCTION NO. 70: Please see Attachment
– Response to Staff’s Request No. 70, which provides a detailed list of wildfire-related
work groups in which Idaho Power participates.
The response to this Request is sponsored by Mitch Colburn, Vice President,
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 44
REQUEST FOR PRODUCTION NO. 71: Please answer the following about the
Enterprise Omnichannel Notification System ("EONS") tool:
a. Please provide the in-service date of the EONS tool;
b. Please explain if the Company has utilized the tool since the in-service date;
c. Please provide any documentation of customer alerts sent/proposed to be sent
through the tool;
d. Please provide a worksheet that breaks down the tool costs by year since
implementation to date; and
e. Please provide a worksheet that breaks down expected cost for the tool by year
for 2023 through 2026.
RESPONSE TO REQUEST FOR PRODUCTION NO. 71:
a. EONS was placed in service on May 2, 2022.
b. The EONS tool has been used several times since the in-service date. The primary
use has been for ad hoc outage event information sent to customers impacted by
outages, before, during, and after events occur. EONS has sent campaigns to
customers in Public Safety Power Shutoff (“PSPS”) zones regarding the upcoming
fire season and outage preparedness. One campaign was sent to customers in a
PSPS zone for an actual PSPS event, however the event was cancelled prior to
any de-energization occurring.
c. See Attachment 1 – Response to Staff Request No. 71
d. See Attachment 2 – Response to Staff Request No. 71
e. See Attachment 2 – Response to Staff Request No. 71

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 45
The response to this Request is sponsored by Ryan Donnelly, Customer
Experience Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 46
REQUEST FOR PRODUCTION NO. 72: Please explain the expected increase in
the incremental costs for Weather Forecasting Personnel from Version 4 of the WMP to
Version 5 for the years 2023 through 2025.
RESPONSE TO REQUEST FOR PRODUCTION NO. 72: There is no expected
increase in the forecast of incremental costs for Weather Forecasting Personnel from
Version 4 to Version 5 of the WMP. As shown below, the amounts forecasted for 2023-
2025 are identical across the two versions:
Cost Forecast from 2022 WMP (Version 4)

Cost Forecast from 2023 WMP (Version 5)

The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 47
REQUEST FOR PRODUCTION NO. 73: Please explain how much the Company
spent to have additional audits done for all pruning work performed in wildfire risk zones.
See Colburn at 46. Please also explain if these expenses were included in the original
cost estimates for vegetation management. Please provide supporting workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 73: In 2022, the Company
spent $20,075 on vegetation audits in wildfire risk zones and in 2023 has spent $9,085
as of June 30th. The expenses associated with vegetation audits were included in the
original incremental cost estimates under “Enhanced Vegetation Management” in the
Wildfire Mitigation Plan; however, the costs are less than anticipated due to contracted
labor constraints last year. The Company conducted a random sample and only
performed audits on 15 percent of the work performed in wildfire risk zones. In 2023, the
Company plans to complete audits for 100 percent of vegetation work performed in
wildfire risk zones. Please see Attachment – Response to Staff’s Request No. 73 for
workpapers for audits performed in 2022.
The response to this Request is sponsored by Mitch Colburn, Vice President,
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 48
REQUEST FOR PRODUCTION NO. 74: As part of the Fuel Reduction program,
please describe if there was any cost sharing between partners. If any, please provide a
worksheet detailing how costs were allocated between partners.
RESPONSE TO REQUEST FOR PRODUCTION NO. 74: As of July 2023, there
has been no cost sharing and no expenses associated with the Fuel Reduction Program.
Idaho Power continues to work with the National Forest Foundation on coordinating and
developing work plans for fuel reduction work in the Boise National Forest near Idaho
Power owned facilities. Idaho Power will provide an update of this project to Commission
Staff as part of the pre-fire season meeting in advance of the 2024 wildfire season.
The response to this Request is sponsored by Mitch Colburn, Vice President,
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 49
REQUEST FOR PRODUCTION NO. 75: Please provide all workpapers used to
develop Larkin's Load Research and Forecasting Workpaper in electronic format with all
formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 75: Please see Confidential
Attachments 1-2 for the load research data discussed in pages 6-8 of Larkin’s Load
Research and Forecasting Workpaper. Confidential Attachment 1 includes data used to
derive the group coincident demand factors. Confidential Attachment 2 includes data
used to derive system coincident demand factors.
The entire breadth of data that is integrated through the sales and load forecast
process and discussed in Larkin’s Load Research and Forecasting Workpaper is
analyzed and stored in various and customized software environments. The source code
for data derivation and extraction is based on a structured query language (“SQL”) or
proprietary Oracle language (“DML”). As such, in order to accommodate this request, the
Company has compiled Excel-formatted regression output and analysis files that feed
into the major components of the Company’s sales and load forecast.
Please see Attachment 3 to this request for the output of the irrigation regression
model. The remaining workpapers used to develop Larkin’s Load Research and
Forecasting Workpaper are provided in the Company’s responses to Request Nos. 76 –
79. The flow of data included in Attachment 3 and other regression output files is as
follows:
- “Data” tab: all source data used in regression
- “Coeff” tab: variable beta coefficient, variable standard error, variable t-statistic,
variable p-statistic

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 50
- “Mstat” tab: model performance statistics
- “Err” tab: actual and predicted values of dependent variable with residuals.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 51
REQUEST FOR PRODUCTION NO. 76: Please provide all workpapers used to
develop the Company's Weather Normalization discussed on page 6 of Larkin's Load
Research and Forecasting Workpaper in electronic format with all formulas intact and
enabled. Please include all data used as inputs and identify the source of the data.
RESPONSE TO REQUEST FOR PRODUCTION NO. 76: Please see the
attachment provided in response to this request for the source data used to develop the
Company’s Weather Normalization discussed on page 6 of Larkin’s Load Research and
Forecasting Workpaper.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 52
REQUEST FOR PRODUCTION NO. 77: Please provide all workpapers used to
develop the Company's Residential Forecast Model discussed on pages 7-8 in Larkin's
Load Research and Forecasting Workpaper in electronic format with all formulas intact
and enabled. Please include all source data used as inputs and identify the source of the
data.
RESPONSE TO REQUEST FOR PRODUCTION NO. 77: Please see Attachment
1 to this request for the source data used in the residential forecast, as well as regression
model output and model statistics. A key is included in the tab labeled "index”. In addition,
please see Attachment 2 to this request for the formulas used in the residential model.
Because the calculations are done in a specific regression software, an Excel file format
is not available.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 53
REQUEST FOR PRODUCTION NO. 78: Please explain the regression modeling
method and provide the regression models used to develop the Company's Residential
Forecast Model discussed on pages 7-8 in Larkin's Load Research and Forecasting
Workpaper in electronic format with all formulas intact and enabled. Please include all
models that were compared and provide the rationale for selecting the final model and
regression coefficients.
RESPONSE TO REQUEST FOR PRODUCTION NO. 78: The Company uses a
statistically adjusted end-use model (“SAE”) specification for the residential class. This
leverages appliance-specific usage information and is sorted by heating equipment
(XHeat variable), cooling equipment (XCool variable), and all other household load
(XOther variable). These variables are then statistically adjusted through an Ordinary
Least Squares (“OLS”) regression framework. All model variations are included in the
attachment to this response. The final model is selected by model statistics that represent
a blend of model parsimony, goodness of fit, and residual analysis.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 54
REQUEST FOR PRODUCTION NO. 79: Please provide all workpapers used to
develop the Company's Commercial and Industrial Forecast Models discussed on pages
8-9 in Larkin's Load Research and Forecasting Workpaper in electronic format with all
formulas intact and enabled. Please include all source data used as inputs and identify
the source of the data.
RESPONSE TO REQUEST FOR PRODUCTION NO. 79: Please see Attachments
1 – 6 of this response. These attachments include the source data used in the regression
estimation of the forecast of the primary commercial and industrial categories. Each
attachment includes regression model output and model statistics. The flow of data
included in these attachments is as follows:
- “Data” tab: all source data used in regression
- “Coeff” tab: variable beta coefficient, variable standard error, variable t-statistic,
variable p-statistic
- “Mstat” tab: model performance statistics
- “Err” tab: actual and predicted values of dependent variable with residuals.
The response to this Request is sponsored by Jordan Prassinos, Manager
Load Forecast and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 55
REQUEST FOR PRODUCTION NO. 80: Please explain the regression modeling
method and provide all regression models used to develop the Company's Commercial
and Industrial Forecast Models discussed on pages 8-9 in Larkin's Load Research and
Forecasting Workpaper in electronic format with all formulas intact and enabled. Please
include all models that were compared and provide the rationale for selecting the final
model and regression coefficients.
RESPONSE TO REQUEST FOR PRODUCTION NO. 80: The forecasting models
for commercial and industrial classes are evaluated annually. Comparisons are done
outside the model within Idaho Power’s databases and coding and, as a result, no
additional workpapers are available. However, the methodologies used to evaluate the
models are described below.
The dependent and independent variables are refreshed with updated Company
data (sales, energy efficiency, customer counts, price, and weather) and from third-party
data providers (economic and demographic). The models process the new data, and the
statistical metrics and forecast are compared to the previous output. In the ideal scenario,
the structure of the model will provide a simple update of the forecast. However, there are
instances where the existing structure is not adequate for either statistical parameters or
forecast output, or both. In other words, there are individual customer/segment changes
that are not adequately explained by the independent variables.
When this occurs, the models are evaluated to isolate the root cause and then
modified to capture the new dynamic. The dependent variable (a customer or segment)
could be removed from the forecast population for independent forecast, alternate

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 56
independent variables could be evaluated for capturing the change, or both of these
strategies could be employed if required.
Due to impacts of COVID-19, the 2022 regression modeling showed that recorded
data was inconsistent to trends. Previously well-performing structures and variables no
longer performed satisfactorily, and the impacts were variable across customer
segments. For example, the COVID-19 indicator variable ceased to provide value for
some models, which required different variables for explanation.
Historically, the manufacturing models for commercial and industrial classes have
performed well with independent variables reflecting economic output, exports,
warehouse, and dairy activity. However, due to the impact of COVID-19, these variables
were not performing adequately in the models. Aside from the energy variable impact, the
lockdown disruptions impacted the entire supply chain of economic data reporting. During
this time, government fiscal expenditures increased, and agency rulings impacted
operations and energy use in a variable manner. For example, operations and energy
use were impacted differently for essential vs. non-essential businesses. Normally, the
causality of the government (“GOV”) variable for the manufacturing industrial model is not
as strong as the aforementioned variables. However, in periods of volatility and increased
influence of fiscal funds and regulation, the GOV variable is a stronger fit to the model.
Other independent variables in the manufacturing models serve to remove the
exogenous influence of a non-economic factor on the dependent variable. For example,
the warehouse variable captures the center of the supply chain, determining and
regulating the ebb and flow of manufacturing energy use. In addition, the Chapter 7
bankruptcies variable captures the economic distress periods.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 57
For service segment models, the baseline drivers are demographic and population
growth characteristics for schools, hospitals, retail, etc. Population is influenced by
economic activity in the territory, and it is dependent upon health of manufacturing
functions and their underlying drivers. This is particularly true of exporters of products like
frozen potatoes or dairy, which provide for external fund flows and feed the growth in
service infrastructure. As a result, the service segment models were not only impacted by
the shutdown of schools and businesses due to COVID but also by the change in
manufacturing output.
For all models/segments, electricity price is considered. However, it is not always
significant and sometimes non-performing.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company.

DATED at Boise, Idaho, this 18th 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 SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 58
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 18th day of July 2023, I served a true and correct
copy of Idaho Power Company’s Response to the Second 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 SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 59
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 SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 60
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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IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 61
Federal Executive Agencies
Peter Meier
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585
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Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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Stacy Gust, Regulatory Administrative
Assistant