20230804IPC to ICIP 10-21.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

August 4, 2023

VIA ELECTRONIC FILING

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-23-11
Idaho Power Company’s General Rate Case

Dear Ms. Noriyuki:

Enclosed for electronic filing, please find Idaho Power Company’s Response to the
Second Production Request of the 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
confidential attachments to these requests to the secure FTP site to allow parties to view
the requested information remotely unless otherwise noted in the response.

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,

Megan Goicoechea Allen
MGA:sg
Enclosures
RECEIVED
2023 AUGUST 4, 2023 4:37PM
IDAHO PUBLIC
UTILITIES COMMISSION

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Second Production Request of the Industrial Customers of Idaho Power
(“ICIP”) dated July 14, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 10:
At page 7 of her testimony, Ms. Grow references "our [Idaho Power's] seven peer
utilities." Please provide the written criteria and documentation used to select the seven
listed utilities as Idaho Power's "peer utilities." Please also explain in narrative form the
rationale for selecting the listed utilities as Idaho Power's "peer utilities."
RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
The Company did not establish written criteria when selecting the seven peer
utilities. These seven utilities were chosen as peer utilities because they are investor-
owned utilities of similar size and geographically close to or adjacent to Idaho Power.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Engineering, Planning and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
REQUEST FOR PRODUCTION NO. 11:
At page 16 of her testimony, Ms. Grow observes that, "Since the Company's last
general rate case the Company has shared $126,752,809 of earnings with its customers
under the ADITC/Revenue Sharing Mechanism." Please identify the dollar amount of the
shared earnings that were used to fund the Company's pension or retirement plans.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
As discussed in the Direct Testimony of Company witness Matthew T. Larkin [at
6-7], pursuant to Order Nos. 30978 and 32424 the pension balancing account was
reduced by $68,148,692, as earnings above a 10.5 percent return on equity were used
to offset future rate increases associated with pension deferrals.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
REQUEST FOR PRODUCTION NO. 12:
At page 23 of her testimony Ms. Grow presents Figure No. 6 showing "Net Electric
Plant in Service." That Figure has superimposed a line representing the Company's
annual depreciation expense. The two data points present a relatively smooth and steady
increase over the decade with one exception. In the 2021 - 2022 year the annual
depreciation expense line takes a sharp out-of-trend jump relative to the trend line for
plant in service. Please explain the reason for this disparate increase in annual
depreciation expense relative to net plant in service.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
The 2022 depreciation expense reflected in Figure No. 6 of Ms. Grow’s testimony
does not reflect any accounting adjustments made to accelerated depreciation expense
for Bridger coal-related assets resulting from Commission Order No. 35423.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
REQUEST FOR PRODUCTION NO. 13:
Ms. Grow comments on a "recent downgrade by Moody's" at page 28 of her
testimony. Please provide copies of all communications between the Company and
Moody’s for the time period beginning January 1, 2022 through today.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
Communications related to the July 26, 2022, credit rating downgrade of Idaho
Power Company by Moody’s Investor Services that were not conducted telephonically
consisted of the publication of a credit opinion by Moody’s Investor Services. This credit
opinion is attached to this response as “CONFIDENTIAL Attachment 1 - ICIP DR No. 13
- Credit Opinion - Idaho-Power-Company - 26Jul22.”
In addition, the Company has made presentations and provided the following
CONFIDENTIAL materials to Moody’s. The requested information is highly confidential.
It will be made available to ICIP at Idaho Power's corporate headquarters. Please contact
Tami White at [phone] or David Fewkes at [phone] to arrange a time to
review the requested material.
No. Description CONFIDENTIAL ATTACHMENT
2 Financial forecast dated March 25,
2022
2022-2026 IPCo Published BB FF 3-25-
22.xlsx
3 Financial forecast narrative dated
March 25, 2022
2022-2024 IDA LTF Published Memo BB-
Rating Agency Final.docx
4 Financial forecast dated June 2023 2023-2027 IPC Published BB FF Rating
Agency.xlsx
5 Financial forecast narrative dated
June 2023
2023-2027 IDA LTF Published Memo
BB-Rating Agency.docx
6 Presentation dated April 12, 2022 2022 Moody’s Presentation Deck.pdf
7 Email correspondence re: Moody’s
walk forward report
Moody's 8-24-22 email.pdf
8 Moody’s walk forward report Walk-Forward Report for IDACORP, Inc
Annual 2021.xlsm
9 Email dated 6-13-2023 with
presentation dated 6-20-2023
Moody's 2023 presentation.pdf

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6

The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.
.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 14:
Also on page 28 Ms. Grow references a “recent note from Standard and Poor's
("S&P") downgrading its liquidity assessment of the Company." Please provide copies of
all communications between the Company and Standard and Poor's for the time period
beginning January 1,2022 through today.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14:
Communications related to the February 7, 2023, downgrade of Idaho Power
Company’s liquidity assessment by S&P Global Ratings that were not conducted
telephonically consisted of the publication of a research update by S&P Global Ratings.
This update is attached to this response as CONFIDENTIAL Attachment 1 – Response
to ICIP DR No. 14 - RatingsDirect.pdf.
In addition, the Company has provided and presented the following
CONFIDENTIAL materials to S&P. The requested information is highly confidential. It will
be made available to ICIP at Idaho Power's corporate headquarters. Please contact Tami
White at [phone] or David Fewkes at [phone] to arrange a time to review
the requested material.
No. DESCRIPTION CONFIDENTIAL ATTACHMENT
2 Financial forecast dated March 25,
2022
2022-2026 IPCo Published BB FF 3-
25-22.xlsx
3 Financial forecast narrative dated
March 25, 2022
2022-2024 IDA LTF Published
Memo BB-Rating Agency Final.docx
4 Financial forecast dated June 2023 2023-2027 IPC Published BB FF
Rating Agency.xlsx
5 Financial forecast narrative dated
June 2023
2023-2027 IDA LTF Published
Memo BB-Rating Agency.docx
6 Presentation dated April 13, 2022 2022 S&P Presentation Deck.pdf
7 Email dated June 14, 2023, re draft
of S&P publication
FW_ SPGCONFIDENTIAL – Pre-
Publication Draft - Idaho Power
8 Attachment to email dated June 14,
2023
Pre-Publication Draft - Idaho Power -
13 June 2023 comments.pdf

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
9 Email dated June 13, 2023, with
attached June 22, 2023,
presentation
2023 S&P presentation deck.pdf

The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
REQUEST FOR PRODUCTION NO. 15:
Please provide the current Moody's rating and the current Standard and Poor's
liquidity assessment for each of the seven peer utilities Ms. Grow identified on page 7 of
her testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
The Company does not collect and keep current such information from this specific
peer group, which is being used to compare system reliability measures, not liquidity or
credit measures. Further, the Company does not subscribe to Moody’s Investor Services
credit ratings services and does not have the reports available to provide for this peer
utility group. Current information may be available directly from Moody’s as part of a paid
subscription or publicly as companies typically provide such information in annual reports,
other Securities and Exchange Commission filings, or on their corporate websites.
Similarly, in the case of Standard and Poor’s, credit ratings and the inclusion of
liquidity assessments within those credit ratings, are available for public consumption
directly from S&P Global Ratings, as part of a paid subscription.
CONFIDENTIAL Attachment 1 to ICIP Request No. 13, page 10, provides Moody’s
ratings for Avista Corporation, NorthWestern Corporation, Portland General Electric and
Puget Sound Energy, Inc. as of July 26, 2022. Also, workpaper file “McKenzie Idaho
Power Exhibit File.xlsm” on tab “Proxy Group Risk Measures” available on the Company’s
FTP site includes the March 28, 2023, S&P corporate rating of the Company’s ROE peer
group, which includes Avista Corporation, NorthWestern Corporation, and Portland
General Electric.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 10
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 11
REQUEST FOR PRODUCTION NO. 16:
At page 29 of her direct testimony Ms. Grow reports that, "immediately following
the last GRC [General Rate Case]" the company began increasing its equity ratio to
achieve a 55 percent equity ratio as recently as year end 2022. Please identify the equity
ratio the Commission approved in the Company's last GRC. Please provide copies of all
communications between the Company and the Commission since its last GRC
addressing the Company's equity ratio.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16:
Commission Order No. 32426 in Case No. IPC-E-11-08, the Company’s last GRC,
approved a Settlement Stipulation entered into by the Company, Commission Staff and
several intervenors. The specific rate of return components such as an equity ratio are
not identified in either the Order or the Settlement Stipulation.
Since its last GRC, the Company has not had any communications with the
Commission addressing its equity ratio.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 12
REQUEST FOR PRODUCTION NO. 17:
Please provide the current equity ratio for each of the seven peer utilities Ms. Grow
identified on page 7 of her testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17:
The Company does not collect such information from this specific peer group,
which is being used to compare system reliability measures, not capitalization structure.
The current equity ratio of each of the peer utility companies identified are available within
each of those entities’ Annual Reports on Form 10-K and/or their FERC Form 1 reports,
as applicable. In order to ensure the most accurate and current equity ratios, the
Company encourages parties to view them in the utilities’ most recent reports, which are
available online or by direct request from those utilities.
Also, note that, Exhibit No. 10 to the direct testimony of Adrien McKenzie presents
the December 31, 2022, capital structure of the Company’s ROE peer group, which
includes Avista Corporation, NorthWestern Corporation, and Portland General Electric.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 13
REQUEST FOR PRODUCTION NO. 18:
At page 32 of her testimony Ms. Grow is asked to identify the options available to
customers to "help them manage their energy costs." Has the Company conducted any
analyses or studies as to whether the adoption of its proposed Residential Price
Modernization plan will have any impact on its customers' ability to manage their energy
costs? If so, please provide copies of all such analyses, studies and supporting
workpapers. Has the company conducted any analyses or studies as to the ability of its
customers to manage their energy usage if the proposed Residential Price Modernization
Plan is adopted? If so please provide copies of all such analyses, studies and supporting
workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
No, the Company has not conducted any analyses or studies specific to the impact
of the Residential Price Modernization Plan’s impact on customers’ ability to manage their
energy costs. The options described on page 32 of Ms. Grow’s testimony would continue
to be available to customers. As described starting on page 22 of Mr. Anderson’s
testimony, the Company did conduct a bill impact analysis associated with the Residential
Price Modernization Plan, which has been provided as Exhibit No. 54 to the Direct
Testimony of Grant Anderson.
The response to this Request is sponsored by Connie G. Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 14
REQUEST FOR PRODUCTION NO. 19:
At page 23 of her testimony Ms. Grow states, "In addition, environmental mandates
require the replacement or retrofitting of aging equipment with technology that is often
more expensive." For the time period since the conclusion of the company's last general
rate case, please identify each "environmental mandated" Ms. Grow is referencing and
the associated "equipment" that such mandate requires to be replaced and/or retrofitted.
Please quantify the dollar impact of each referenced instance of equipment that has been
or is being replaced due to each such "environmental mandate" Ms. Grow is referencing
in her testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19:
Idaho Power’s activities are subject to a broad range of federal, state, regional,
and local laws and regulations designed to protect, restore, and enhance the quality of
the environment. Additionally, since the conclusion of the Company’s last rate case Idaho
Power has completed over 114,000 capital projects, many of which were at least partly
related to environmental requirements. Therefore, it is not possible for Idaho Power to
manually sort through each of the approximate 114,000 completed projects to determine
their relation to the multitude of environmental regulations to which Idaho Power is
subject. A comprehensive list of these projects was provided to parties in the Company’s
Response to Idaho Public Utilities Commission Staff’s Request No. 35. The above-
referenced statement in Ms. Grow’s testimony is generally referring to the fact that
environmental regulations have resulted in investment in the Company’s system since
the conclusion of its last rate case.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 15
In light of the breadth of completed projects and the extensive and often
overlapping nature of environmental regulations, Idaho Power offers the following
examples of environmentally-driven investments completed since the conclusion of its
last general rate case as generally referenced by Ms. Grow in her testimony:
 Selective Catalytic Reduction (“SCR”) systems installed on Units 3 and 4 of
the Jim Bridger Power Plant as a result of the Regional Haze Rule
implemented by the United States Environmental Protection Agency. Idaho
Power is currently collecting these amounts in rates, therefore there is no
dollar impact included in this application.
 Fish ladder construction at the Upper Malad hydro facility as a result of
Article 408 of the facility’s federal license. The total amount closed to plant
was $11.3 million.
 White sturgeon conservation hatchery investment to supplement sturgeon
populations in the Middle Snake River in accordance with Article 406 of the
Swan Falls hydro facility’s federal license. The total amount closed to plant
was $6.0 million.
The response to this Request is sponsored by Ryan N. Adelman, Vice President
Power Supply, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 16
REQUEST FOR PRODUCTION NO. 20:
Does the Company consider carbon emissions reduction one such environmental
mandate that is referenced by Ms. Grow at page 23 of her testimony?
RESPONSE TO REQUEST FOR PRODUCTION NO. 20:
No. While the Company has set short-term, medium-term, and long-term carbon
emission reduction goals for itself, Idaho Power is not currently subject to an
environmental mandate to reduce carbon emissions resulting in retrofitting or
replacement of equipment.
The response to this Request is sponsored by Ryan N. Adelman, Vice President
Power Supply, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 17
REQUEST FOR PRODUCTION NO. 21:
Regardless as to whether the Company views carbon emissions reduction as a
mandate or not, please identify each of the Company's carbon emissions reduction
activities and quantify the dollar amount spent by the Company on each such project.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21:
As stated in the prior response, Idaho Power has set internal short-term, medium-
term, and long-term carbon emission reduction goals for itself which are laid out in the
Company’s Environmental, Social and Governance (“ESG”) report.1 The ESG report
discusses some of the ways Idaho Power is working to reduce carbon intensity. For
example, by 2030, Idaho Power projects that 75 percent of its passenger cars and forklifts
(including all new purchases) will be electric as will 35 percent of other fleet vehicles under
8,500 pounds. As of December 31, 2022, 55 percent of passenger cars, 32 percent of
forklifts and 4 percent of other vehicles under 8,500 pounds in Idaho Power’s fleet are
electric. Idaho Power has invested approximately $11 million in capital and maintenance
expenses associated with electric vehicles.
In addition, the Company’s Integrated Resource Plan (“IRP”) allows the Company
to economically evaluate decisions related to its existing resources as well as future
resources over a 20-year time horizon. The early exit of coal-fired generation at both the
Valmy and Bridger power plants was shown to be cost-effective with the additional benefit
of reduced carbon emissions. The 2021 IRP preferred portfolio calls for continued
integration of more cost-effective clean resources to ensure Idaho Power can reliably
serve its customers. The Company’s most recent resource additions (purchasing energy

1 https://www.idahopower.com/energy-environment/environmental-stewardship/sustainability/

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 18
from a 120-MW solar plant and utility-scale battery energy storage systems) were the
result of a competitive process to select the most cost-effective resource for customers,
while at the same time contributing to reduced carbon emissions.
The response to this Request is sponsored by Ryan N. Adelman, Vice President
Power Supply, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 19
DATED at Boise, Idaho, this 4th day of August 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 20
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 4th day of August 2023, I served a true and correct
copy of Idaho Power Company’s Response to the Second 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

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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
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U.S. Mail
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FTP Site
X Email [e-mail]

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

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

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IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 21
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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[e-mail]

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 22
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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

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

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IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 23
Federal Executive Agencies
Peter Meier
c/o U.S. Department of Energy
1000 Independence Ave., S. W.
Washington, DC 20585
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Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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_______________
Stacy Gust, Regulatory Administrative Assistant