20230726IPC to Staff 81-106.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

July 26, 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
Third 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 26, 2023 3:54PM
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 some of the attachments in Response to Requests Nos. 85, 87, 89, 91, 95,
and 99 to Idaho Power Company’s Response to the Third Production Request of the
Commission Staff dated July 26, 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 26th day of July, 2023.

LISA D. NORDSTROM
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE
STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY
ACCOUNTING TREATMENT.
)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-11

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Third Production Request of the Commission Staff (“Commission” or
“Staff”) dated July 5, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 81: Please provide a detailed explanation of
the Company's calculation of uncollectible accounts. Please also include workpapers in
Excel format with all formulas intact.
RESPONSE TO REQUEST FOR PRODUCTION NO. 81: The Company
calculated a 10-year average (2013 – 2022) of the yearly percentage of uncollectible
accounts (or bad debt expense) divided by revenue. The 10-year average of 0.351
percent was then multiplied by the 2023 forecasted revenue amount of $1,641,862,697.
The result of $5,770,879 is the forecasted amount of 2023 uncollectible account expense.
Please see Excel file “Attachment – Response to Staff Request No. 81” for
calculation and formulas.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 82: Please provide an explanation of the
increases in payroll expenses in April 2022 and September 2022 according to the
workpaper provided by Company Witness Noe "Payroll Annualizing Adjustments 2023."
RESPONSE TO REQUEST FOR PRODUCTION NO. 82: The increase in payroll
expense in the months of April and September 2022 was due to three pay periods
occurring in those months whereas the other months only had two pay periods.
The response to this Request is sponsored by Kelley Noe, Regulatory Consultant,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 83: Please explain why December 2022
payroll expenses were annualized multiplying by 13 instead of by 12 in the workpaper
provided by Company Witness Noe "Payroll Annualizing Adjustments 2023."
RESPONSE TO REQUEST FOR PRODUCTION NO. 83: The December 2022
payroll expense was multiplied by 13 because December had two pay periods and there
are 26 pay periods per year. Multiplying by 12 would understate payroll expense.
The response to this Request is sponsored by Kelley Noe, Regulatory Consultant
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 84: Please provide the plan documents for
each of the Company's qualified retirement plans.
RESPONSE TO REQUEST FOR PRODUCTION NO. 84: The requested
information is provided in Attachment 1 – Response to Staff Request No. 84 – 401k Plan
Document and Attachment 2 – Response to Staff Request No. 84 – Pension Plan
Document.
The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 85: Please provide the Summary Plan
Description for each of the Company's qualified retirement plans.
RESPONSE TO REQUEST FOR PRODUCTION NO. 85: The requested
information is provided in Confidential Attachment 1 – Response to Staff Request No. 85
and Confidential Attachment 2 – Response to Staff Request No. 85.
The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 86: Please provide statistics regarding
employee turnover rate from 2018 through 2022. Please indicate percentages of
employees each year who retired, were terminated, or voluntarily resigned.
RESPONSE TO REQUEST FOR PRODUCTION NO. 86: The chart below
provides employee turnover statistics from 2018 through 2022, excluding seasonal
employees.
Turnover Rate Category 2018 2019 2020 2021 2022
Retirement Turnover 2.90% 2.90% 3.80% 3.10% 2.90%
Voluntary Turnover (excluding retirement) 1.80% 1.60% 2.10% 2.90% 3.30%
Overall Voluntary Turnover 4.70% 4.40% 5.80% 6.00% 6.20%
Involuntary Turnover 1.30% 1.30% 0.70% 0.80% 1.00%
Overall Turnover 6.00% 5.70% 6.60% 6.80% 7.20%

The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 87: Has the Company conducted any
comparative analyses of employee retention rates for companies offering defined benefit
plans vs. companies offering defined contribution plans. If yes, please provide the
analysis. If not, why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 87: Idaho Power monitors
turnover data at peer companies through the Company’s industry associations and did a
turnover survey for 2022 in early 2023 with the Human Resource leader group at Western
Energy Institute (“WEI”). There were 20 respondents, including Idaho Power. The
Company researched whether these companies had open defined benefit pension plans
and compared turnover rates of those with and without. Of note, three of the companies
reported anonymously, so the number analyzed was reduced to 17, 12 of which had open
defined benefit pension plans in 2022. The average turnover rate of those companies with
defined benefit pension plans was 5.25 percent compared to 6.14 percent at companies
without. While this information supports the notion that retention rates tend to be lower
for companies with a defined benefit pension plan, it is important to recognize several of
the responding companies have closed pension plans with active employees who are still
under the closed pension plan. That said, one could reasonably assume the difference in
retention rates could be even greater than the attached analysis suggests.
The Company has provided additional information on the WEI turnover study and
the Company’s pension analysis; please see Confidential Attachment 1 – Response to
Staff Request No. 87 and Confidential Attachment 2 – Response to Staff Request No. 87.
The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 88: Please provide statistics regarding the
percentage of employees who participate in the defined contribution plan.
RESPONSE TO REQUEST FOR PRODUCTION NO. 88: As of plan year end
2022, 94.6 percent of employees were participating in the defined contribution plan.
The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 89: Please outline the incentive criteria for
non-executive employees and provide copies of any incentive plans or policies.
RESPONSE TO REQUEST FOR PRODUCTION NO. 89: The annual Employee
Incentive Plan has a target payout of six percent of base pay and includes three equally
weighted components: operational, customer service, and profit-sharing. As described on
page 27 of Ms. Griffin’s direct testimony the only components that are included in the test
year are the components directly related to identifiable customer benefits, which in this
case are network reliability and customer satisfaction. These components are included in
the test year at the 2 percent target (medium) incentive level.
Operational and Customer Service Goals: The operational and customer service
goals include the customer satisfaction goal and the network reliability goal, and the profit-
sharing opportunity is based on qualified annual earnings. The customer satisfaction goal
will be based on the 12-month average of the customer relationship index (“CRI”). As
described in more detail on pages 9-13 of Mr. Hanchey’s direct testimony, the CRI
measures the Company’s performance from the perspective of the customer and is based
on a rolling 12-month average for the period beginning January 1 through December 31.
The index consists of five specific questions asked of Idaho Power’s customers by an
independent survey company and addresses issues, such as overall satisfaction, quality,
value, advocacy, and loyalty. The CRI goal for each year is published in the Employee
Incentive Plan Goals document.
The network reliability goal considers the frequency and duration of customer
outages. It is measured using the number of interruptions longer than five minutes

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
experienced during the year by customers. The annual network reliability goal is
published in the Employee Incentive Plan Goals document.
Profit-Sharing Goal: Profit-sharing payment is based on IDACORP’s achievement
against predetermined financial targets. The annual net income target percentage
payouts are published in the Employee Incentive Plan Goals document. Any performance
payout between the levels published in the Employee Incentive Plan document will be
prorated. While the Profit-Sharing component is included in the market evaluation of
compensation, it is not included in the Company’s revenue requirement, and therefore
not funded by customers.
Plan details on participation eligibility, payment of awards, and the effect of
termination on potential awards can be found in the Employee Incentive Plan documents,
which are provided as Attachment 1 – Response to Staff Request No. 89 and Confidential
Attachment 2 – Response to Staff Request No. 89.
The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
REQUEST FOR PRODUCTION NO. 90: Please provide details regarding any
occurrence where severance pay was issued in years 2018 through 2022, if applicable.
RESPONSE TO REQUEST FOR PRODUCTION NO. 90: The Company does not
maintain a formal severance program, but there are circumstances when terminated
employees are offered severance in exchange for signing an agreement broadly releasing
claims. The Company may offer severance related to organizational restructuring or when
an employee has been unsuccessful in their job despite coaching and performance
management and the employee’s best efforts, combined with other complicating risk
factors. However, the Company most frequently offers severance as a cost-mitigation tool
to reduce the likelihood of unnecessary expenditure in defending frivolous claims when
the Company believes the claims or potential claims can be resolved for a more
reasonable cost in the form of a severance payment.
The circumstances surrounding these severance payments are highly confidential
personnel matters, and the discussions related to these payments are attorney-client
privileged. Therefore, only dates and payment amounts are available for on-site review.
The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
REQUEST FOR PRODUCTION NO. 91: Please provide job descriptions and
salaries for all executive officers and members of the board of directors.
RESPONSE TO REQUEST FOR PRODUCTION NO. 91: Please see Confidential
Attachment 1 – Response to Staff Request No. 91.
The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
REQUEST FOR PRODUCTION NO. 92: The Company released a Mobile
Application ("App") "...due to the increasing shift in customers' preferences toward
accessing their account and service-related information on the go." Hanchey Direct at 15.
Please respond to the following about the App:
a. Please provide any surveys, focus group, or other supporting documentation used
to inform the Company of customer preferences of accessing information on the
go. In the response, please include the results of any surveys conducted including
population size, how the survey was distributed, and response rate by distribution
method;
b. Please provide a supporting worksheet that details the actual amount spent on
development, implementation, maintenance, and advertisement of the App by year
since the development of the App to date;
c. Please provide a brief description and a supporting worksheet that breaks down
forecasted spend by year for 2023-2025 for the App;
d. Please explain if the Company conducted a cost benefit analysis for its App. If yes,
please provide the cost benefit analysis. If not, please explain why not;
e. Please explain how the Company promotes its App to customers. Please provide
supporting documentation;
f. Since it launched, please provide a worksheet detailing the number of customers
who have downloaded the App by month, the number of customers who use the
App on a monthly basis, the number of customers who pay their bills monthly
through the App, the number of customers who signed up for push notifications by
month through the App; and

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
g. Please provide an example of how a customer's bill displays through the App.
RESPONSE TO REQUEST FOR PRODUCTION NO. 92:
a. J.D. Power Customer Satisfaction Studies have shown a positive correlation
between Idaho Power’s customer satisfaction and the use of My Account. With 97
percent of Americans owning a mobile phone1 and 37 percent of individuals
typically using their mobile phone to access the internet,2 the implementation of a
mobile application was a logical next step for the Company. Additionally, according
to the results of a 2019 Chartwell Survey, which is included as Attachment 1 –
Response to Staff Request No. 92a, 53 percent of responding utilities already
offered an option for customers to pay via mobile application, and another 24
percent of responding utilities were considering offering a mobile application within
the next two years.
A 2018 Customer Satisfaction Survey by Chartwell also reported notable increases
in customer satisfaction for utilities offering digital self-service options. On average,
customers who were aware that their utility offered a mobile application
experienced an overall positive increase in customer satisfaction of 8 percent, and
for customers within the 35-65 age bracket, the positive increase in customer
satisfaction was higher at 11 percent. This survey also noted that for respondents
who had downloaded and used their utility’s mobile application to view and pay
their bills, these respondents, on average, rated their utility more favorably in
regard to ease of doing business and customer loyalty. A copy of this survey is
included as Attachment 2 – Response to Staff Request No. 92a.

1 Pew Research Center, Mobile fact sheet, April 7, 2021.
2 Pew Research Center, Mobile Technology and Home Broadband 2019, June 13, 2019.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
Similarly, in recent quarterly customer relationship surveys conducted by Burke,
customers reported an increasing use of their mobile phones to access My
Account (an increase from 16 percent in mid-2019 to approximately 27 percent in
mid-2023); a summary of these results is included as Attachment 3 – Response to
Staff Request No. 92a.
Burke conducts its quarterly customer relationship surveys using phone and online
methodologies, and the annual number of interviews conducted is detailed below.
1. 942 in 2019
2. 947 in 2020
3. 955 in 2021
4. 949 in 2022
b. Please see Attachment 1 – Response to Staff Request No. 92b and note that the
maintenance costs do not include internal labor costs related to supporting the
mobile application, as the Company does not currently track the number of support
hours dedicated to its mobile application.
c. Please see Attachment 1 – Response to Staff Request No. 92c.
d. Yes, Idaho Power did conduct a cost benefit analysis for the mobile application,
which has been provided as Attachment 1 – Response to Staff Request No. 92d.
This cost benefit analysis only included quantifiable costs and benefits, and
therefore does not account for the non-quantifiable benefits associated with
increased customer satisfaction, which was the primary driver for implementing the
technology.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
e. Research shows that customers between the ages of 18 and 45, and who live in
more urban areas, are more likely to download a mobile application. Most of the
Company’s marketing for its mobile application is digital and targets residential
customers, with a few select advertising channels focusing more heavily on
residents within Treasure Valley and the aforementioned age demographic. A few
of the Company’s mobile application advertisements have also focused on
targeting business and agricultural customers. A some of the marketing tactics
used for the Company’s mobile application include, but are not limited to:
1. App store prioritization through keywords and advertisements
2. Paid search (bringing the app to the top of a customer’s Google search for
related information)
3. Digital advertisements during two separate campaign months
4. Bill inserts
In addition to the marketing tactics mentioned above, Idaho Power also employs
many organic and no-to-low-cost advertising tactics such as, but not limited to:
1. Mobile application-related flyers and signage for public events
2. Digital advertising on Company-owned channels such as its website, within
My Account, and using social medial and email platforms
3. IVR hold messages
4. Public presentations
5. Word-of-mouth from customer-facing employees
The Company’s mobile application is also mentioned in many different types of
customer communications, examples of which are included as Attachment 1 –

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
Response to Staff Request No. 92e.
f. Please see Attachment 1 – Response to Staff Request No. 92f.
g. Please see Attachment 1 – Response to Staff Request No. 92g.
The response to this Request is sponsored by Bo Hanchey, VP Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19
REQUEST FOR PRODUCTION NO. 93: For My Account information accessed
via desktop computers and by the mobile website, please provide a worksheet separated
by desktop computer and mobile website access detailing the number of customers who
access their information monthly, the number of customers who pay their bills monthly
through My Account, and the number of customers who have signed up for text
notifications by month.
RESPONSE TO REQUEST FOR PRODUCTION NO. 93: Please see Attachment
1 – Response to Staff Request No. 93. Aside from mobile application-specific analytics,
the Company does not currently track whether payments or enrollment in text notifications
occurs on a desktop computer or mobile device. However, analytics of My Account
indicate that approximately 53 percent of users access the website using a desktop and
approximately 47 percent access the website using via mobile device.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 20
REQUEST FOR PRODUCTION NO. 94: Hanchey Direct at 29-30 describes a
reduction in annual call volumes is likely from various self-serve features implemented by
the Company. Please explain if the App and My Account has created any savings in labor
due to the reduction in calls to the Customer Service Center.
RESPONSE TO REQUEST FOR PRODUCTION NO. 94: As more customers sign
up for My Account and utilize the Company’s mobile application and other self-service
options, the Company anticipates that the number of customers needing to call the
Company’s Customer Service Center and interact with Customer Service
Representatives will decrease in the future. Because there are multiple factors that drive
the number of customer interactions up and down over time, including customer growth,
the Company is unable to isolate the impact of any individual factor.
The response to this Request is sponsored by Bo Hanchey, VP Of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 21
REQUEST FOR PRODUCTION NO. 95: On page 24 of Hackett's Direct testimony,
Hackett states "[t]he Company is requesting in this case to include $146.8 million for 120
MW of battery capacity plus an additional $28 million investment to account for
performance degradation over time that will ensure the batteries maintain the 120 MW of
capacity." Please respond to the following:
a. Please explain how the additional $28 million will be utilized to preserve the
batteries' capacity. Please provide supporting workpapers that detail how $28
million would be spent; and
b. Please explain if battery preservation costs were included in the least-cost least-
risk analysis in Case No. IPC-E-22-13.
RESPONSE TO REQUEST FOR PRODUCTION NO. 95:
a. The Company’s initial investment included the purchase and installation of
sufficient battery capacity to eliminate additional battery augmentation to maintain
the 120 MW nameplate rating for at least five years. That beginning of life
investment is made up of $146.8 million for the 120 MW nameplate capacity plus
the $28 million investment in additional investment to mitigate performance
degradation. The total investment of $174.8 million included in the Company’s
request in this case accounts for the performance degradation guarantees that
Powin, LLC must contractually meet the nameplate energy and capacity
performance measures over time. Please see Confidential Attachment 1 –
Response to Staff Request No. 95 and Confidential Attachment 2 – Response to
Staff Request No. 95 for the Battery Energy Supply Agreements between Idaho
Power and Powin, LLC for both the Hemingway 80 MW battery energy storage

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 22
system (“BESS”) and Black Mesa 40 MW BESS, respectively. Exhibit E to each
Battery Energy Supply Agreement details the contract price associated with the
initial battery storage investments necessary to maintain the 120 MW nameplate
rating. The remaining costs associated with the total $174.8 million investment
were related to the balance of plant activities. Furthermore, Exhibit F to each
Battery Energy Supply Agreement details the performance guarantee over time.
b. Yes. The investment to account for performance degradation over time was a
component of the levelized cost of the resource evaluated as part of the evaluation
of all project submittals discussed in Case No. IPC-E-22-13.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 23
REQUEST FOR PRODUCTION NO. 96: Please provide the 2023 Integrated
Resource Plan ("IRP") analysis and workpapers used to support the Company's rationale
to expand the summer season to the end of September.
RESPONSE TO REQUEST FOR PRODUCTION NO. 96: Idaho Power initially
identified the first half of the month of September as a high-risk period in the sensitivity
analyses conducted for Case No. IPC-E-21-32 (Application, Table 3), to assess the
Company’s Demand Response Programs parameters based on the 2023 load and
resource year.
The 2023 IRP preliminary analysis utilized to develop the highest-risk hours for
defining proposed time-of-use (“TOU”) periods is provided in the Excel file labeled
“Attachment – Response to Staff’s Request No. 96.” The “LOLP” tab includes the hourly
Loss of Load Probabilities (“LOLP”) and resulting monthly Loss of Load Expectations
(“LOLE”) based on the 2025 load and resource year. The chart below shows the monthly
LOLE values as a percentage of the annual average for the summer season.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 24
This chart shows that 47 percent of the risk in the 2025 load and resource year
resides in the month of July. As seen, this analysis shows that there is more risk in the
month of September than there is in the month of June (by ~1 percent), supporting the
decision to include September in the summer season.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution, and Resource Planning Director.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 25
REQUEST FOR PRODUCTION NO. 97: Please provide the analysis performed
by the power supply planning team for the 2023 IRP used to identify highest risks hours
for all schedules containing time-of-use ("TOU") components. Aschenbrenner Direct at
21.
RESPONSE TO REQUEST FOR PRODUCTION NO. 97: Please see the Excel
file labeled “Attachment – Response to Staff’s Request No. 96” for the analysis to identify
the highest-risk hours for defining proposed TOU periods. The “TOU_Results” tab
includes a summary by season of (1) the highest-risk hours and (2) the highest-risk
consecutive block.
In preparing this response, the Company found that the analysis used to develop
the TOU definitions for its residential TOU periods varied slightly from the analysis used
to develop TOU for Schedules 9 and 19. In a previous version of this analysis, the highest-
risk consecutive block defined the winter/non-summer season’s highest-risk hours as 7
a.m. to 9 a.m. and 6 p.m. to 9 p.m. These hours were used to develop the Company’s
residential rate design proposal.
As provided in the file “Attachment – Response to Staff’s Request No. 96,” the
highest-risk consecutive block defined the winter/non-summer highest risk hours as 6
a.m. to 9 a.m. and 5 p.m. to 8 p.m. These hours were used for developing the Company’s
large commercial and industrial rate design proposals. The Company would recommend
updating the definition of on-peak hours for residential TOU to align with the updated
analysis, which would align the definitions of on-peak for all schedules containing TOU
energy charges.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 26
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 27
REQUEST FOR PRODUCTION NO. 98: Please explain why the proposed
expanded summer season for customers consuming energy is different than the
proposed summer season in the Company's concurrent export credit rate filing, Case No.
IPC-E-23-14. Please provide supporting workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 98: The proposed expanded
summer season for customers consuming energy is June 1 – September 30, and the
summer season for the export credit rate in Case No. IPC-E-23-14 is June 15 –
September 15. The dates identified for the export credit rate align with the highest risk
hours as initially identified in Case No. IPC-E-21-32 (Application, Table 3). The
Company’s class cost-of-service study allocates costs on a monthly basis; therefore, the
tariff schedule includes summer and non-summer months defined on a monthly basis.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 28
REQUEST FOR PRODUCTION NO. 99: Please respond to the following
questions about the Company's proposed shift of Demand Side Management ("DSM")
labor costs from the energy efficiency rider to base rates.
a. Under the proposed adjustment, would the Company include labor cost in its cost
effectiveness calculations?
i. If not, why not?
ii. If yes, please explain how the Company would calculate cost effectiveness
of its DSM offerings while factoring in labor cost and provide example
workpapers demonstrating the calculations in Excel format with equations
intact and enabled.
b. Please provide the annual DSM labor expenses from 2017 to 2022;
c. Please include all calculations used to apply the 2% wage increase year-to-year
from 2017 to date;
d. For the proposed Schedule 91 Energy Efficiency Rider rate, please provide a
forecast for the beginning balance as of January 1, 2024, revenues, expenditures
by category (i.e., incentive, marketing, evaluations, etc.), expenditures by
programs, and ending balance by month for 2024, 2025, and 2026 in Excel format
with all equations intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 99:
a. Yes. The Company will continue to use all costs associated with its programs when
calculating cost-effectiveness regardless of funding source.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 29
i. N/A
ii. As shown in Appendix 2 of the DSM Annual Reports, expenses for
all DSM activity is made up of Idaho Rider, Oregon Rider, and Non-Rider
funds. These Non-Rider funds include, but aren’t limited to, O&M expenses.
The expenditures for each program and DSM activity are tracked using a
work order number. Idaho Power staff working on a DSM program will
continue to track labor expenses using the work order system but the
account information will be updated to use a non-Rider O&M account rather
than the Idaho Rider account. An example of this can be seen in the
Irrigation Efficiency Rewards program.
Since the inception of the Irrigation Efficiency Rewards program, the
program has been supported by a variety of staff including a program
specialist, engineer, and agricultural representatives. Many of the positions
that support the program existed prior to the implementation of the Rider
and as such, only incremental time over and above time from historical
positions has been charged to the Rider. In the DSM 2022 Annual Report
Supplement 1: Cost-Effectiveness, a detailed breakdown of expenses is
found in Table 2. The labor and administrative expenses account for
$374,951 of the $2,080,027 total expenses in the Irrigation Efficiency
Rewards program. Of those labor and administrative expenses, $55,284
was charged to a non-Rider O&M account. As shown on page 55 of
Supplement 1: Cost-Effectiveness, the total expenses of $2,080,027 (which
includes Rider and non-Rider funding) are included in the cost-effectiveness

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 30
analysis. See Attachment 1 – Response to Staff Request No. 99 for the
cost-effectiveness work paper.
When possible, employees charge their time directly to the program
work orders they are directly working on as is the case with the Agricultural
Representatives. However, if an employee works on several programs, they
may charge to an overhead work order. An example would be a Residential
and Commercial Energy Advisor speaking to a commercial customer about
New Construction, Retrofits, and Custom Projects. These expenses are
tracked and included in the portfolio cost-effectiveness.
To summarize, incorporating labor costs associated with different
funding sources is already built into the Company’s process when
calculating cost-effectiveness. Therefore, moving the labor costs to be
funded by base rates, and accounting for those costs in the cost-
effectiveness calculations, will not materially change the Company’s
current process.
b. Please see Attachment 2 provided for this response.
c. Please see Attachment 2 provided for this response.
d. Please see Confidential Attachment 3 provided for this response.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 31
REQUEST FOR PRODUCTION NO. 100: Please respond to the following
regarding the Company's Schedule 5 on-peak/off-peak price differential.
a. Please provide the Brattle study and accompanying workpapers referenced in
Anderson Direct at 19; and
b. Please provide an analysis, in Excel format with formulas enabled and intact, of
how the Schedule 5 summer 4.0x and non-summer 1.5x align with actual Company
expenditures during those times.
RESPONSE TO REQUEST FOR PRODUCTION NO. 100: Please see the
following responses regarding the Company’s Schedule 5, Time-of-Use service:
a. Please see the PDF file labeled “Attachment – Response to Staff’s Request No.
100” for the Brattle study referred to in Anderson Direct at 19.
b. The Company’s proposed Schedule 5, Residential Time-of-Use on- and off-peak
price ratios are not aligned with actual Company expenditures. Rather, the
proposed TOU price ratios were intended to promote a behavioral response for
customers to shift usage from the on-peak to off-peak time period. The Company
recognizes this design is not cost based and accordingly has proposed a modified,
time-differentiated, Fixed Cost Adjustment.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 32
REQUEST FOR PRODUCTION NO. 101: Please provide a complete list of the
tools the Company's Field Observers have available in wildfire risk zones.
a. Please provide a supporting worksheet that includes the tool name, total quantity
of tools, purchase date, and cost. Please separate the Mobile Weather Kits
purchased in 2022 from the other tools;
b. Please discuss tangible or intangible benefits that the Mobile Weather Kits have
provided; and
c. Please explain if the Company plans to purchase additional Mobile Weather Kits
in 2023 through 2025. If so, please provide number of kits and expected costs by
year.
RESPONSE TO REQUEST FOR PRODUCTION NO. 101:
a. The requested information is included in the attachment to this request.
b. Based on the inherently disruptive nature of power outages, Public Safety Power
Shutoff (“PSPS”) events are carefully evaluated by a Company assessment team
to balance wildfire risk with potential impacts on customers and communities. The
Company only plans to use PSPS as a last resort and relies on data from fixed
weather stations and Field Observers (“FOB”) to help inform de-energization
decisions. FOBs use mobile weather kits—weather instrumentation that includes
a handheld wind meter and compass—to help ensure consistent weather and wind
observations are made and to supplement information from fixed weather stations.
In 2022, a PSPS was anticipated for approximately 643 customers in the Pocatello
area and FOBs were deployed to provide real-time information for the weather
event. The feedback of wind speeds and observations of moisture from an

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 33
approaching thunderstorm was instrumental in helping the assessment team
determine that de-energization was not necessary and, as a result, the event was
cancelled.
c. Consistent with the Company’s most recent wildfire mitigation cost deferral filing,
the Company envisioned spending $10,000 (purchasing approximately 33 weather
kits) in 2023 and no additional spending on mobile weather kits in 2024 and 2025.3
The Company will continue to train Idaho Power employees to serve as FOBs in
the coming years.
The response to this Request is sponsored by Mitch Colburn, Vice
President of Planning, Engineering, and Construction, Idaho Power Company.

3 In the Matter of Idaho Power’s Application for Review of the Company’s Current Wildfire Mitigation Plan
and Authorization to Defer Newly Identified Incremental Wildfire Mitigation Costs, IPC-E-22-27, p. 15.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 34
REQUEST FOR PRODUCTION NO. 102: Please explain the expected increase
in the incremental costs for Weather Forecasting Personnel from Version 4 of the Wildfire
Mitigation Plan ("WMP") to Version 5 for the years 2023 through 2025.
RESPONSE TO REQUEST FOR PRODUCTION NO. 102: Please see the
Company’s response to Staff’s Request for Production No. 72.
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 THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 35
REQUEST FOR PRODUCTION NO. 103: The Company requests to continue
deferring only incremental vegetation management Operation and Maintenance ("O&M")
expenses. Tatum Direct at 7. Does the Company expect to defer any incremental costs
for the other components of the WMP?
a. If no, please explain why the Company expects no incremental costs; and
b. Please provide estimated cost of incremental cost of vegetation management O&M
by year for 2023-2025.
RESPONSE TO REQUEST FOR PRODUCTION NO. 103: In this case, the
Company is requesting to continue to defer incremental vegetation management
and insurance costs from new baseline levels, as noted in Tatum Direct at 7.
a. Beyond the request in this case, the Company has not yet assessed the need for
deferral of other WMP costs.
b. Please see the table below for the Company’s forecast of incremental vegetation
management expenses for 2023-2025. Also please note that the 2023 incremental
amount is calculated using the 2019 base, as authorized under the most recent
authorized WMP deferral in Docket No. IPC-E-22-27 (Order No. 35717), and the
2024 and 2025 incremental amounts are calculated using the updated base, as
proposed in this Company’s Application in this case.
Incremental Costs ($000s) 2023 2024* 2025*
Vegetation Management

15,658

10,551

14,091
*2024 and 2025 incremental amounts measured from the new proposed baseline in this case

While the values in the table reflect the Company’s current forecast of future
incremental vegetation management costs, Idaho Power will continue to look for

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 36
ways to minimize this cost category going forward without compromising its
vegetation management targets and wildfire risk mitigation objectives.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 37
REQUEST FOR PRODUCTION NO. 104: Please respond to the following about
the Emergency Outage Notification System tool described in Hanchey Direct Testimony
at 17:
a. Please explain how the Emergency Outage Notification System identifies
customers in affected areas of planned and unplanned outages;
b. Please explain if the Company can automatically enroll certain customers into
outage notifications for this tool;
c. Please explain what kind of load shed events are notified by this tool;
d. Please explain if the Company can use this tool to identify and notify critical
customers in the public safety power shutoffs areas; and
e. Please provide the cost to implement and maintain this tool. Please provide
supporting workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 104: The Company
acknowledges it created confusion by incorrectly referring to EONS as the Emergency
Outage Notification System. This was an error; there is only one EONS and it stands for
Enterprise Omni-Channel Notification System. Please see the Company’s response to
Staff’s Production Request No. 105 for the requested information about the EONS
system.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 38
REQUEST FOR PRODUCTION NO. 105: Please respond to the following about
Enterprise Omnichannel Notification System ("EONS") tool:
a. Please explain how the EONS tool identifies customers in affected areas of
planned and unplanned outages;
b. Please explain if the Company can automatically enroll certain customers into
outage notifications for this tool;
c. Please explain what kind of load shed events, if any, are notified by this tool;
d. Please explain if the Company can use this tool to identify and notify critical
customers in the public safety power shutoffs; and
e. Please provide the cost to implement and maintain this tool. Please provide
supporting workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 105:
a. Idaho Power has two methods of identifying customers for communications using
EONS. For planned and unplanned outages, the most common method is to
upload a comma-separated values (.csv) file of impacted customers provided by
Idaho Power’s dispatch. Additionally, Idaho Power sends a customer list to the
EONS tool daily with the following information: service point, city, state, zip, region,
rate category, customer type, contact (email address or phone number), contact
type, Standard Industrial Classification code, a critical facility indicator, device,
feeder and Public Safety Power Shutoff (“PSPS”) zone. Idaho Power can filter
customers within EONS on any of these fields to create a list of customers to
contact. This method was developed for PSPS and load shed events to ensure
that events and contact lists can easily be broken down by feeder or PSPS zone.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 39
b. EONS is an internal communication and alert management tool, in which
customers do not enroll. Rather, EONS is used primarily to communicate about ad
hoc and unplanned outages, which are often of an urgent nature with urgent
communication needs.
c. No load shed events have occurred to date since the implementation of EONS. If
a load shed event were to occur, the Company anticipates using EONS to send
customers as much information and notification as possible. Customers would
receive any EONS notifications in addition to any outage alerts (text, email, or push
notifications) they are enrolled in.
d. Idaho Power identifies critical facilities in the daily file that is uploaded into EONS.
Critical facilities have not received targeted notifications through EONS, but they
are included in all PSPS notifications. Additionally, Idaho Power’s Energy Advisors
or Regional Customer Relations Managers (“RCRM”) work one-on-one with critical
facilities throughout a PSPS event. Key customers (outside of critical facilities) are
not identified in EONS. However, Energy Advisors or RCRMs reach out to these
customers via phone.
e. Please see Attachment 1 – Response to Staff Request No 105.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 40
REQUEST FOR PRODUCTION NO. 106: In Company Witness Hanchey's Direct
testimony, he described the Emergency Outage Notification System. Hanchey Direct at
17. Please answer the following:
a. Please explain the difference between the Emergency Outage Notification System
tool and the EONS tool used for the Wildfire Mitigation program;
b. Please provide a worksheet that details date of use, the use of the tool for
outages/load shed events other than wildfire outages/load shed events, number of
customers impacted per event, how customers were notified (i.e., text or voice
messaging), yearly cost to use tool, FERC account booked;
c. Please explain how the Company uses its different outage notification systems;
and
d. Please provide supporting worksheet that includes the functions of each
notification system.
RESPONSE TO REQUEST FOR PRODUCTION NO. 106:
a. As noted in the Company’s response to Staff’s Production Request No. 104, the
reference to an Emergency Outage Notification System was an error. EONS
stands for Enterprise Omni-Channel Notification System, and this is the tool the
Company uses for Public Safety Power Shutoff (“PSPS”) alerts.
b. For a worksheet with details of EONS use, please see Attachment 1 – Response
to Staff Request No. 106. For costs, please refer to Attachment 1 – Response to
Staff Request No. 105. EONS is booked to FERC account 921000.
c. EONS is primarily used for ad hoc outage event information sent to customers
impacted by outages, before, during, and after the event occurs. The Company

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 41
has also used EONS for PSPS “campaigns” sent to customers in PSPS zones
regarding the upcoming fire season and outage preparedness. Last year, the
Company used EONS to contact customers in a PSPS zone for an actual PSPS
event; however, the event was cancelled prior to de-energization. EONS serves a
particular purpose among Idaho Power’s different notification tools—it allows for
rapid, targeted, and/or repeat communications. Additionally, whereas the
Company’s other alert tools are limited to a certain number of communications per
hour and/or a character limit on communication length, EONS allows for frequent
and sufficient communication for those situations in which explanation, education,
and outage information are necessary—making the tool ideal for PSPS
communications.
The Company uses an automated dialer system as the main form of
communication before a planned outage. Through this system, an automated voice
call is sent to all customers impacted by the outage (for whom the Company has
a phone number). This is used in addition to any personalized outreach to
customers conducted via Idaho Power’s Energy Advisors.
Additionally, customers can enroll in text, email, and/or push notifications to
be notified of outages at any of the addresses on their account. Notifications are
sent when the power goes out, when an estimated time of restoration (“ETR”) is
added or changed, and when power is restored to most customers.
Lastly, customers can enroll in text notifications for a particular outage
through the Company’s outage map. Notifications are sent for ETR updates and
when power is restored to most customers.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 42
d. The communication tools described in response (c) are summarized in Attachment
2 – Response to Staff Request No. 106.
The response to this Request is sponsored by Bo Hanchey, VP of Customer
Operations, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 43
DATED at Boise, Idaho, this 26th 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 THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 44
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 26th day of July 2023, I served a true and correct
copy of Idaho Power Company’s Response to the Third Production Request of the
Commission Staff to Idaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Dayn Hardie
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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

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

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

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

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

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

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 45
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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

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

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

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

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

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

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

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD 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
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]
[e-mail]

Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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

Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702

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

Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]

IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

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

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 47
Federal Executive Agencies
Peter Meier
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

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

Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Stacy Gust, Regulatory Administrative
Assistant