20230728IPC to Staff 107-114.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

July 28, 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
Fourth 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:cd
Enclosures
RECEIVED
Friday, July 28, 2023 3:46:56 PM
IDAHO PUBLIC
UTILITIES COMMISSION

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Fourth Production Request of the Commission Staff (“Commission” or
“Staff”) dated July 7, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 107: Please provide the Net-to-Gross Tax
Multiplier workpaper in Excel format with formulas intact and enabled. Exhibit No. 35, Line
1097, Column F.
RESPONSE TO REQUEST FOR PRODUCTION NO. 107:
Please see the attached Excel file labeled Attachment 1– Response to Staff
Request No 107.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 108: Please provide the individual revenue
requirement models for Valmy, Bridger, and Battery Accumulated Deferred Income Tax
Credits ("ADITC") Mitigation in Excel format with formulas intact and enabled. Exhibit No.
35, Lines 40, 41, and 42.
RESPONSE TO REQUEST FOR PRODUCTION NO. 108: Please see the
attached Excel files, labeled “Attachment 1– Response to Staff Request No 108”,
“Attachment 2– Response to Staff Request No 108”, for Valmy and Bridger respectively.
To determine the Battery Accumulated Deferred Income Tax Credits (“ADITC”) Mitigation
amount, Idaho Power calculated the System Revenue Requirement with and without the
120 MW battery projects. Please see Attachments 3 and 4 for the System Revenue
Requirement and Jurisdictional Separation Study (“JSS”) with and without the 120
megawatts (“MW”) battery projects. Attachments 5 through 13 are the work papers used
in the calculation of the System Revenue Requirement without the 120 MW battery
projects.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 109: Please provide the status of relicensing
Hells Canyon Complex.
RESPONSE TO REQUEST FOR PRODUCTION NO. 109:
As explained in the Company’s Hells Canyon Complex (“HCC”) Relicensing
Expenditures 2022 Annual Report, filed on February 28, 2023, pursuant to Order No.
34031 in Case No. IPC-E-16-32, in June 2022, the Federal Energy Regulatory
Commission (“FERC”) issued a notice of intent to prepare a supplemental Environmental
Impact Statement (“EIS”) in accordance with the National Environmental Policy Act.
FERC indicated that the supplemental EIS would address the new and revised measures
proposed by the Clean Water Act § 401 certification settlement, the conditions contained
in the Oregon and Idaho water quality certificates, and the information provided in the
draft biological assessments. FERC also reinstated informal consultation with the United
States Fish and Wildlife Service (“USFWS”) and the United States Department of
Commerce National Oceanic and Atmospheric Administration’s National Marine Fisheries
Service (“NMFS”) under Section 7 of the Endangered Species Act (“ESA”). In the Notice
of Intent (“NOI”), FERC predicted that the draft supplemental EIS would be published in
June 2023 and the final supplemental EIS in December 2023; an updated NOI has not
yet been issued.
Idaho Power continues to work with Idaho and Oregon on measures to provide
reasonable assurance that any discharges from the HCC will comply with applicable state
water quality standards and associated measures identified in the final § 401 certifications
and continues to cooperate with the USFWS, NMFS, and FERC in an effort to address
ESA concerns. Once the final EIS and ESA consultation is complete, FERC can issue a

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
license. The Company is unable to predict the timing of issuance by FERC of any license
order but believes issuance will be in 2024 or thereafter.
The response to this Request is sponsored by Brett Dumas, Environmental Affairs
Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 110: Please provide the journal entries and
workpapers of the Allowance for Funds Used During Construction ("AFUDC") for Hells
Canyon Complex relicensing. Please include the amount booked to Construction Work in
Progress from 2018 to 2022.
RESPONSE TO REQUEST FOR PRODUCTION NO. 110:
As a point of clarification, the Company is not seeking a prudence review of Hells
Canyon Complex relicensing costs as part of this case. The only Hells Canyon Complex
relicensing-related costs at issue in this case is a request to continue recovery of
previously approved Hells Canyon Complex relicensing AFUDC collection, which is not
related to the AFUDC amounts booked in the requested time period.
AFUDC is calculated within the Company’s accounting software and therefore is
not available in a workpaper format. As an alternative, Idaho Power has provided as
Attachment 1 – Response to Staff Request No. 110 the Hells Canyon Complex
relicensing AFUDC transactions from 2016, which consists of those transactions since
the Company’s request for prudence of Hells Canyon Complex relicensing expenditures
in Case No. IPC-E-16-32, through 2022. As can be seen in Attachment 1, AFUDC is
recorded to Federal Energy Regulatory Commission (“FERC”) Account 107 -
Construction Work in Progress. The offset to these entries is either FERC Account 419.1
- Allowance for Other Funds Used During Construction or FERC Account 432 - Allowance
for Borrowed Funds Used During Construction. The following details the AFUDC
calculation process.
AFUDC is applied to individual work orders on a monthly basis via system
calculation within Idaho Power’s accounting software, PeopleSoft. This system

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
calculation is accomplished by applying the applicable allowance for other funds (“AO”)
and allowance for borrowed funds (“AB”) rates for the month to the average work order
balance provided by the cumulative beginning of month balance and the end of month
balance for the work order. The system calculation of AFUDC allows for partial month
proration for the opening month of a work order and the closing month of a work order.
Monthly AO and AB rates are calculated and reviewed for accuracy. Once rates are
reviewed, the rates are input into PeopleSoft. A separate team member then queries
PeopleSoft for the AO and AB rates that were input and verifies that the rates were input
into the system correctly.
Please see Attachment 2 – Response to Staff Request No. 110 for the total Hells
Canyon Complex relicensing expenditures incurred from 1997 through 2022 by cost
element, including AFUDC. Please see Attachment 3 – Response to Staff Request No.
110 for the Hells Canyon Complex relicensing amounts recorded to Construction Work in
Progress, by work order, from 2018 to 2022.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 111: Exhibit Nos. 34 and 35 include Oregon
Income Tax to be paid by Idaho customers. Please provide documentation outlining
source of income from an Oregon source.
RESPONSE TO REQUEST FOR PRODUCTION NO. 111:
Because Idaho Power operates in more than one jurisdiction, the only direct source
of income from Oregon is Oregon retail revenues (see Brady Exhibit 27 and Noe Exhibit
35, Table 4), while Other Revenues (Noe Exhibit 35, Table 4) and Operating Expenses
(Noe Exhibit 35, Tables 5-8) are primarily allocated amongst the jurisdictions. Therefore,
a portion of state taxes is allocated to each jurisdiction rather than a direct assignment;
accordingly, Oregon customers are allocated a portion of Idaho income tax.
The response to this Request is sponsored by Kelley Noe, Regulatory Consultant,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 112: Please provide Schedule 72 —
Generator Interconnections to Public Utility Regulatory Policies Act of 1978 ("PURPA")
Qualifying Facility Sellers actual revenues and expenses for 2018 to 2023 to date in Excel
format with formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 112:
See the table below of actual revenues collected through Schedule 72 from 2018
to 2023 to date. These amounts are not calculated therefore an Excel spreadsheet is not
provided.
Year Schedule 72 Revenues
2018 1,578,645.07
2019 1,657,816.57
2020 1,745,870.84
2021 1,759,235.75
2022 1,832,348.13
2023* 940,499.84
*Amounts thru June 30
Idaho Power does not separately track actual costs incurred for operation and
maintenance (“O&M”) expenses on QF interconnections. Once these projects are placed
into service, they are deemed a part of Idaho Power’s plant, the same as any other plant
that is non-customer funded; and the cost of maintaining (or replacing) this equipment is
paid for by all Idaho Power customers, with an offsetting revenue credit for the amounts
collected above through the Schedule 72 O&M charge assessed to QF interconnections.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 113: Please detail the cash working capital
("CWC") method used. Also, please provide the workpapers used to calculate CWC
amounts in Exhibit No. 34 in Excel format with formulas intact and enabled. Exhibit No.
34, Lines 288-305.
RESPONSE TO REQUEST FOR PRODUCTION NO. 113:
Idaho Power’s 2023 test year does not include a request for a general cash working
capital allowance. Rather, the amounts included in Exhibit No. 34, lines 288-305, reflect
three discreet revenue requirement categories: Account 151: Fuel Inventory, Accounts
154 & 163: Materials & Supplies (Plant Inventory), and Account 165: Prepaid Items. A
different test year methodology was applied to each of these categories as follows:
Account 151: Fuel Inventory
Please see the attached Excel file “Attachment 1 - Fuel Inventory Forecast 2023.”
This file was also provided with the workpapers of Company witness Kelley Noe. Fuel
inventory reflected in the 2023 test year was calculated by first determining optimal coal
inventory levels for the Bridger and Valmy power plants based on expected operating
conditions. The Company then applied the expected cost-per-ton to these optimal
inventory amounts to determine a dollar value, then added required oil inventory at the
Bridger plant to determine the final 2023 test year amount of $24,704,689 contained in
cell H22 of the attachment.
Accounts 154 & 163: Materials & Supplies (Plant Inventory)
The methodology for developing test year Materials & Supplies (“M&S”) is detailed
on page 24 of Exhibit No. 26 to the Direct Testimony of Company witness Matthew Larkin.
First, as reflected in Column 3 of Exhibit No. 34, inventory related to the Boardman Power

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
Plant was removed from actual year-end 2022 data in the amount of $967,717. As shown
in the formulas in cells E290 to E293, this amount was removed proportionately to actual
year-end 2022 amounts. The Company then applied a three-year Compound Average
Growth Rate (“CAGR”) to these adjusted amounts to determine the Forecast Adjustment
in Column 6 of Exhibit No. 34 in the amount of $10,145,311. As demonstrated in
“Attachment 2 – Materials and Supplies,” three-year CAGRs were calculated for Accounts
154 and 163 in the amounts of 12.78 percent and 6.83 percent, respectively. These
CAGRs were then used to determine the $10,145,311 value that was proportionally
applied to the various M&S categories.
Accounts 165: Prepaid Items
Idaho Power excluded Account 165 from the 2023 test year in its entirety.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
REQUEST FOR PRODUCTION NO. 114: Utilities requesting CWC in rate base
must be able to demonstrate that CWC needs are supplied by investors. Order No. 19333.
Please explain and provide documentation showing how CWC is being supplied by
investors.
RESPONSE TO REQUEST FOR PRODUCTION NO. 114:
Please see the Company’s Response to Staff’s Request No. 113. Idaho Power is
not requesting a general CWC allowance in this case. The above-referenced language in
Order No. 19333 is related to a general CWC allowance request based on a non-specific
lead-lag study, which is not part of Idaho Power’s request in this case. Therefore, the
need to demonstrate that CWC needs are supplied by investors is not applicable.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

DATED at Boise, Idaho, this 28th 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 FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 28th day of July 2023, I served a true and correct
copy of Idaho Power Company’s Response to the Fourth 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 FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
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 FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
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 FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
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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Christy Davenport
Legal Administrative Assistant