20230801IPC to ICIP 1-9.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

August 1, 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
First Production Request of the Industrial Customers of Idaho Power 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
Tuesday, August 1, 2023 4:41:57 PM
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 Request No. 2 to Idaho Power
Company’s Response to the First Production Request of the Industrial Customers of
Idaho Power to Idaho Power Company dated August 1, 2023, contain information that
Idaho Power Company claims is a trade secret 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 1st day of August 2023.

LISA D. NORDSTROM
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 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 FIRST
PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF
IDAHO POWER

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Industrial Customers of Idaho Power
(“ICIP”) dated July 10, 2023, but served on July 11, 2023 herewith submits the following
information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 1: Please provide, in electronic format with
all formulae intact where possible, all workpapers and other documents used in the
development of Idaho Powers Application in this matter.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: The workpapers used in
developing Idaho Power’s Application were provided to the Commission via the
Company’s File Transfer (“FTP”) Site on June 7, 2023. The Company provided ICIP
access to the Company’s FTP site on June 12, 2023.
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
REQUEST FOR PRODUCTION NO. 2: Please provide copies of all
communications between Idaho Power and the Idaho Public Utilities Commission and/or
its Staff regarding Idaho Power's Application in this matter.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see the
attachments containing all substantive communications between Idaho Power and the
Idaho Public Utilities Commission and / or its Staff (“Staff”) regarding the Company’s
Application in this matter. These attachments do not include non-substantive emails (e.g.,
communications regarding parking passes for Staff on-site audit visits) or
communications on which all parties to this case were copied (e.g., overview workshop
and case scheduling).
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
REQUEST FOR PRODUCTION NO. 3: Please provide copies of all responses to
production requests (both formal and informal) provided to any other party to this
proceeding
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: As of July 28, 2023, in
addition to the instant set, Idaho Power has been served with the following discovery
requests:
 First Production Request of the Commission (“IPUC” or “Commission”) Staff
to Idaho Power Company dated June 13, 2023;
 Second Production Request of the Commission Staff to Idaho Power
Company dated June 27, 2023;
 Third Production Request of the Commission Staff to Idaho Power
Company dated July 5, 2023;
 Clean Energy Opportunities (“CEO”) for Idaho’s First Production Request
to Idaho Power Company dated July 7, 2023;
 Fourth Production Request of the Commission Staff to Idaho Power
Company dated July 7, 2023;
 First Production Request of Micron Technology, Inc. to Idaho Company
dated July 7, 2023;
 Second Production Request of the Industrial Customers of Idaho Power to
Idaho Power Company dated July 14, 2023;
 Clean Energy Opportunities for Idaho’s Second Production Request to
Idaho Power Company dated July 14, 2023;
 Fifth Production Request of the Commission Staff to Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
dated July 18, 2023;
 IdaHydro’s First Production Request to Idaho Power Company dated July
20, 2023; and
 Fifth Production Request of the Commission Staff to Idaho Power Company
dated July 28, 2023.
To date, Idaho Power provided responses to Commission Staff’s First Production
Request on June 27, 2023, July 5, 2023, and Supplemental Response on July 27, 2023,
Commission Staff’s Second Production Request on July 18, 2023, Commission Staff’s
Third Production Request on July 26, 2023, and Commission Staff’s Fourth Production
Request and CEO’s First Production Request on July 28, 2023, which have been filed
and served on all parties in accordance with Commission Rules of Procedure 63, 64, and
229. As of a matter of course, copies of all Idaho Power responses to discovery requests
will continue to be served on all parties granted intervention in this docket pursuant to the
terms and requirements of the Protective Agreement in the event the response or
production contains confidential information.
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
REQUEST FOR PRODUCTION NO. 4: Please provide the class cost-of-service
(CCOS) model used by Pawel P. Goralski in electronic format with all formulas intact and
enabled along with all workpapers used to develop used to create CCOS.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see Response to
Request for Production No. 1 in this set. The FTP site includes the Excel versions of the
CCOS exhibits and supporting workpapers.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 5: Exhibit No. 48, P. Goralski IPC, Page 5
of 5, lists a column labeled 'Cost of Service Index'. Please provide an explanation of how
the Index was calculated. Please provide all workpapers and models in electronic format
with all formulae intact used in the calculation of the Index.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see Response to
Request for Production No. 1 in this set for the Excel version of Exhibit No. 48.
The Cost of Service Index is the ratio of the Final Revenue Allocation Average Mills
per megawatt-hour (“MWh”) value for a customer class, divided by the Cost-of-Service
Results Average Mills per MWh for a customer class, as listed on page 2 of 5. Please
note the header lists the value “per kWh” which is a typo.
The ratio represents the revenue allocation as informed by the class cost-of-
service study compared to the final allocation after the cap and spread process. For
example, the Schedule 24 Irrigation Service class cost-of-service result is a revenue
allocation of $194,263,258 with normalized test year sales of 1,864,522,772 kWh, for
average mills per MWh of $104.19 as listed on line No. 11 of page 2 ($194,263,258 /
1,864,522,772 * 1,000). The final revenue allocation for Schedule 24 is $184,423,605
after cap and spread, for average mills per MWh of $98.38 as listed on Line 11 of page 5
($183,423,605 / 1,864,522,772 * 1,000). The Cost of Service Index for Schedule 24 is
$98.38 per MWh / 104.19 per MWh, or 94 percent.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
REQUEST FOR PRODUCTION NO. 6: Exhibit No. 42, P. Goralski IPC, Pages I
and 2, lists row 39 labeled 'Rate of Return - Index'. Please provide an explanation of how
this Index was calculated. Please provide all workpapers and models in electronic format
with all formulae intact used in the calculation of the Index.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Please see Response to
Request for Production No. 1 in this set for the Excel version of Exhibit No. 42.
The “Rates of Return – Index,” row 39, is calculated for each customer class as
the ratio of the class specific rate of return on row 38 to the overall Idaho rate of return
requested in this case, 7.172 percent.
The rate of return is the customer class, or total Idaho, Consolidated Operating
Income on row 36 divided by the Total Rate Base on row 10. For the Idaho total, the
amount is $280,614,102 Consolidated Operating Income / $3,912,569,823 total rate
base, or 7.172 percent.
As an example, the Rate of Return – Index for the Residential class is calculated
by first determining the rate of return of 6.715 percent: $119,698,758 Consolidated
Operating Income / $1,782,680,096 Rate Base, and further divide that result by the
requested Idaho rate of return, 7.172 (6.715 / 7.172) to equal the Rates of Return – Index
amount of 0.936.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
REQUEST FOR PRODUCTION NO. 7: Please explain fully and how each
calculation varies for the 'Cost of Service Index' and the 'Rate of Return - Index' found in
Exhibits 42 and 48.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The calculations vary as
the Cost of Service Index compares the revenue requirement at cost-of-service to the
revenue target determined through the cap and spread process, while the Rates of Return
– Index compares the actual return of the class to the actual return for the State of Idaho.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 10
REQUEST FOR PRODUCTION NO. 8: Which Index, the 'Cost of Service Index'
or the 'Rate of Return - Index', was used in the allocation of rate increases to the customer
classes? Please explain fully rational of why that Index was chosen.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Neither index was used
in the allocation of rate increases, however, the Cost of Service Index represents the
outcome of the proposed revenue change for each class’s class cost-of-service (“CCOS”)
results. The combined steps of completing the CCOS study and then the cap and spread
process determine the final proposed revenue target for customer classes.
CCOS result statistics for test year projected revenue collections and cost
allocations may be found on Exhibit No. 42 in rows 47 – 51. Most of the same information
may be found on page 2 of Exhibit No. 48 summarizing the CCOS results prior to cap and
spread. Proposed changes to customer class revenue requirement are first informed by
CCOS results, then the Cap & Spread process, which applies a floor of 0 percent change
to any customer class, and ceiling of 1.5 times the overall increase, 12.91 percent (8.61
percent x 1.5). Pages 3 and 4 of Exhibit No. 48 are the calculations of the cap and spread
process.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 11
REQUEST FOR PRODUCTION NO. 9(1): The Direct Testimony of Grant
Anderson on page 30, states, "For all rate components, the Company is proposing rates
that represent a uniform 30 percent movement toward the costs to serve" for Large Power
Service. Please explain fully why 30 percent was selected and/or derived.
Also please explain fully why the Company did not propose to move this class to
full Cost-of-Service.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9(1): The uniform 30
percent movement towards cost-of-service informed billing components for Large Power
Service was selected to make incremental progress from the existing rate design towards
cost-of-service.
With gradualism and customer bill impact in mind, the Company did not propose
to move 100 percent towards cost-of-service. Page 6 of Exhibit No. 54 shows average bill
increases between 4 percent and 16 percent for Large Power Service under the
Company’s proposed rate design. Moving this customer class 100 percent towards cost-
of-service would result in average bill increases ranging between 1.5 percent and 30
percent for Large Power Service. Therefore, the Company believes a 30 percent
movement towards cost-of-service informed rates achieves incremental improvement in
rate design while balancing the consideration of individual customer bill impacts.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 12
REQUEST FOR PRODUCTION NO. 9(2): Page 11 of P. Goralski DI presents
Table 1 that indicates the Classification of Purchased Power - PURPA has been changed
from Demand/Energy to 100% Energy. Given the PURPA rate contains both a capacity
portion and an energy portion please explain fully the rationale why PURPA should be
classified as all energy and provide supporting documentation of your analysis.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9(2): Prior classification of
purchased power in the Company’s 2011 general rate case, including PURPA energy
and capacity cost did not classify costs in a manner matching the respective component
of PURPA payment, that is PURPA capacity costs were not classified as 100 percent
demand-related, nor were PURPA energy costs classified as 100 percent energy-related,
instead they followed classification of production plant.
Prior classification of purchased power in the Company’s 2011 general rate case
used a composite allocator, “PP-KWH,” derived from classification of the Company’s
steam, hydraulic, and “other” production generation plant which was consistent with use
of the Idaho jurisdictional load factor to determine the energy classification portion. That
is, 54 percent of production plant was classified as energy-related, and the remainder
was classified as demand-related, resulting in 54 percent of purchased power energy,
and capacity being classified as energy-related in the 2011 general rate case, with the
remainder classified as demand-related
Further, the capacity-related expense listed in the 2011 general rate case test year,
$2,815,214 out of $86,772,920 of account 555.1 Cogeneration & Small Power Production

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 13
cost,1 represented capacity payments for contracts which had a levelized capacity
payment independent of energy generation for generators such as hydro and biomass,
and were contracts executed in the 1980s which utilized a different Commission-approved
methodology for capacity payment structure. As contracts have expired since the 2011
general rate case, upon their renewal all contracts were transitioned to current,
Commission-approved methodology to include the capacity payment on a combined
basis with the energy rate and are expressed on single, dollars per megawatt-hour values
differentiated between heavy-load and light-load hours, which is the single contract cost
value for any specific hour entered into the Company’s accounting system. The last year
Idaho Power recorded separate capacity payments was 2019.
Payments made for PURPA contracts for both energy and capacity are variable
based on the variable output of the project, thus the Company has classified all PURPA
expense as 100 percent energy-related.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

1 In the Matter of the Application of Idaho Power Company for Authority to Increase Its Rates and
Charges for Electric Service to Its Customers in the State of Idaho, Case No. IPC-E-11-08, NOE Exhibit
No. 26, pg. 12 of 35 (Filed June 1, 2011).

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 14
DATED at Boise, Idaho, this 1st day of August 2023.

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 15
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 1st day of August 2023, I served a true and correct
copy of Idaho Power Company’s Response to the First Production Request of the
Industrial Customers of Idaho Power 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

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FAX
FTP Site
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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 16
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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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

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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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

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[e-mail]
[e-mail]
[e-mail]
[e-mail]

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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FTP Site
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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 17
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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[e-mail]
[e-mail]

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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FAX
FTP Site
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[e-mail]

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

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[e-mail]

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 18
Federal Executive Agencies
Peter Meier
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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FTP Site
X Email [e-mail]

NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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FTP Site
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Stacy Gust, Regulatory Administrative
Assistant