20230808IPC to Staff 115-134.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

August 8, 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
Fifth 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
Wednesday, August 9, 2023 9:27:39 AM
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. 117, 119, 122, and
124 to Idaho Power Company’s Response to the Fifth Production Request of the
Commission Staff dated August 8, 2023, contain information that Idaho Power Company
and a third party claim are trade secrets, and/or business records of a private enterprise
required by law to be submitted to or inspected by a public agency, 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 8th day of August, 2023.

LISA D. NORDSTROM
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH 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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)
)
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CASE NO. IPC-E-23-11

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Fifth Production Request of the Commission Staff (“Commission” or
“Staff”) dated July 18, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 115: Please provide the Idaho Jurisdictional
average net rate base for electric service calculated using a December 31, 2022, test
year end. Please provide all workpapers supporting the calculations in electronic format
with all formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 115: After discussing this
request with Idaho Public Utilities Commission Staff (“Staff”) it was determined that Idaho
Power does not need to provide average net rate base for year-end 2022.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 116: Please update the Company's Idaho
electric revenue requirement models using a December 31, 2022, test year end using
average net rate base. Please provide all workpapers used in the model in electronic
format with all formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 116: After discussing this
request with Idaho Public Utilities Commission Staff (“Staff”) it was determined that Idaho
Power does not need to develop a new electric revenue requirement model using a test
year ending December 31, 2022.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4

REQUEST FOR PRODUCTION NO. 117: Please provide an updated Base Net
Power Expense using a December 31, 2022, test year end using average net rate base.
Please provide all workpapers used to determine Base Net Power Expense in electronic
format with all formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 117: Please see the “FERC
Accounts” tab of Attachment 10 to this request for Base Net Power Supply Expenses by
FERC Account using a 2022 test year. Confidential Attachments 1 – 8 and Attachment
9 contain data used in calculations and/or as inputs into the AURORA model.
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 118: Please provide updated Test Year
Sales Forecast calculations using a December 31, 2022, test year end using average net
rate base. Please provide all load research and forecasting workpapers, including
weather normalization, used to determine the Test Year Sales Forecast in electronic
format with all formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 118: Per discussion with
Staff regarding the Company’s Response to Staff’s Request No. 120, Idaho Power will be
providing the requested information in conjunction with an updated Class Cost-of-Service
(“CCOS”) model based on normalized 2022 inputs no later than August 18, 2023.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6

REQUEST FOR PRODUCTION NO. 119: Please provide an updated Test Year
Retail Sales Revenue forecast using a December 31, 2022, test year end using average
net rate base. Please provide all workpapers used to determine the test year retail sales
revenue forecast in electronic format with all formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 119: Please see
Confidential Attachment 1 to this request for normalized 2022 retail sales revenue.
Confidential Attachment 2 contains workpapers used in the calculation.
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 120: Please provide an updated Cost of
Service Model using a December 31, 2022, test year end using average net rate base.
Please provide all workpapers used to determine Cost of Service Model in electronic
format with all formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 120: Per discussion with
Staff regarding the Company’s Response to Staff’s Request No. 120, Idaho Power will be
providing an updated Class Cost-of-Service (“CCOS”) model based on normalized 2022
inputs no later than August 18, 2023.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 121: Regarding the Company's response to
Production Request No. 5, Confidential Attachment 1, please provide a description of why
legal counsel was needed for each circumstance in 2022.
RESPONSE TO REQUEST FOR PRODUCTION NO. 121: Idaho Power utilizes
outside counsel when necessary for legal advice and/or services related to damage
claims because these require attention and effort similar to a standard court case
(pleadings and hearings, etc.), and the engaged firms have the necessary knowledge of
collection procedures to manage the full collection process. The low volume of work in
this area does not justify a dedicated attorney for these types of matters.
As noted in Confidential Attachment No. 1 to Staff Production Request No. 5, Idaho
Power engaged Stephan, Kvanvig, Stone & Trainor on a contingency basis to pursue
judgments on items over the $5,000 small claims limit. Idaho Power paid actual court
filing fees and service of process fees and paid the firm 1/3 of any amounts they collect.
Idaho Power does not pay outside counsel fees to Stephan, Kvanvig, Stone & Trainor in
instances where they do not successfully collect. Idaho Power engaged Smith + Malek,
PLLC to pursue judgments on items over the $5,000 small claims limit on a flat-rate basis,
with varying flat fees for reaching resolution at different points in the claims recovery
process (i.e., a flat fee for resolution at default judgment, a different flat fee for resolution
at settlement, and a different flat fee if the matter goes to trial).
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 122: Regarding the Company's response to
Production Request No. 5, Confidential Attachment 2, please provide an explanation why
legal counsel was needed for all matters listed in the attached Confidential spreadsheet
"Idaho Power Legal Sample" in 2022.
RESPONSE TO REQUEST FOR PRODUCTION NO. 122: Idaho Power utilizes
outside counsel for legal advice that is beyond the licensure, expertise, or workload
capacity of its in-house attorneys. The Company also utilizes outside counsel where they
have performed prior similar or identical work for other clients, which allows them to
efficiently complete the work. In those circumstances, in-house attorneys engage and
oversee the contracted work of outside counsel in furtherance of the Company’s interests.
Confidential Attachment No. 2 to Staff Production Request No. 5 contains columns
for each legal matter detailing the subject matter, jurisdiction, case number, case name,
and the type of legal advice provided in addition to identifying the firm, attorney and total
amount related to the legal services provided. Idaho Power has provided a more detailed
description in the Confidential Attachment to this response to the extent it can without
negatively impacting the attorney-client privilege. Idaho Power affirms that these legal
matters were necessary for Idaho Power to comply with state or federal law/regulations,
to respond to proceedings initiated against Idaho Power, to protect the interests of
shareowners and customers, or to inform the Company’s legal or operational strategy.
The response to this Request is sponsored by Julia Hilton, Vice President &
General Counsel, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 123: Regarding the Company's response to
Production Request No. 6, Confidential Attachment F, please state the amount spent on
maintenance and amount spent on flights in 2022. Please also provide a log of individual
flights, which includes the cost of each flight and reason for each flight.
RESPONSE TO REQUEST FOR PRODUCTION NO. 123: The maintenance cost
for the Corporate Jet during 2022 was $154,557.12 and $257,402.85 was spent on flights.
Please see “Attachment - Response to Staff Request No. 123” for the 2022 individual
flights and their cost.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company. 

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
REQUEST FOR PRODUCTION NO. 124: Please provide a breakdown of the
costs of cloud seeding from years 2017 to 2022. Please describe the methods used to
facilitate cloud seeding. Please also provide an analysis that outlines the benefits and
reimbursements the Company and its customers have received from cloud seeding.
RESPONSE TO REQUEST FOR PRODUCTION NO. 124: Idaho Power operates
cloud seeding operations to augment the water supply in the Snake River. Operations are
divided into two regions, the Central Mountains and the Upper Snake River Basin. The
Central Mountains region consists of portions of the Payette, Boise, and Wood River
Basins. The Upper Snake River region covers most of eastern Idaho and parts of western
Wyoming.
The following criteria are required for cloud seeding to be effective:
- An abundance of supercooled liquid water (water that is below freezing but
stays in the liquid state) within a wintertime storm.
- A lack of ice nuclei (the object that a snowflake or raindrop forms and grows
around) in the atmosphere.
- Atmospheric lift (air that has an upward vertical motion).
For cloud seeding operations, Idaho Power releases silver iodide (“AgI”) into the
atmosphere to act as ice nuclei in wintertime storms. The release of these microscopic
particles is done via specially modified aircraft and/or specially designed ground
generators. The aircraft are equipped with flares that when burned release AgI directly
into the wintertime storm at levels where the supercooled liquid water is present.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
Ground based generators burn an acetone and AgI solution within a propane flame
that then releases AgI into the atmosphere. The updraft of the wintertime storm transports
the AgI into the cloud and the layers of the storm where supercooled liquid water is
present.
The table below shows cloud seeding project costs from 2017 – 2022. Costs are
divided into Labor, Materials, Purchased Services, and Other. Operational costs of the
program are shared with the Idaho Water Resource Board and local water users, which
is shown in the “Collaborative Funding” row and reflected as an offset to the total costs.

From 2017 to 2022, the total cost to operate cloud seeding operations has
remained relatively unchanged at an average annual cost of $3.5 million. During the same
timeframe, collaborative funding has increased from around $1 million in 2017 to close to
$2.4 million in 2022. Annual costs and collaborative funding amounts are depicted in the
below figure.

1 Increase in Other Expenses is due to High Performance Computer warranty expense.
2 Increase in collaborative funding due to the funding being accrued for the first time at year-end.
Cloud Seeding Costs and Collaborative Funding by Year 
 2017 2018 2019 2020 2021 2022 
Labor  $ 655,265 $ 697,945 $ 776,752 $ 684,528 $ 746,791 $ 816,630 
Materials 199,294 359,431 159,443 260,769 358,734 337,088 
Purchased Services 1,973,294 2,571,365 2,284,634 2,469,150 2,042,966 2,039,621 
Other Expenses 165,690 144,733 168,206 440,2971 193,983 198,237 
Collaborative Funding (1,039,809) (1,353,817) (2,614,927)2 (1,827,854) (1,943,850) (2,385,002) 
Total $1,953,734 $2,419,656 $774,109 $2,026,890 $1,398,624 $1,006,574 

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13

Benefits from cloud seeding were analyzed as a part of the Company’s 2021
Integrated Resource Plan, and the full analysis has been provided in the confidential
attachment to this response. Pages 14-18 of the analysis discuss benefits to
hydrogeneration. More specifically, page 17 notes that the estimated average annual
incremental benefit to hydrogeneration from cloud seeding is about 436,000 megawatt-
hours (“MWh”) per year, or about 1,000 – 4,000 MWh per day. The approximate 5-year
average cost per MWh of generation resulting from cloud seeding operations is $3.66.
The response to this Request is sponsored by Kresta Davis, Water Resources and
Senior Policy Manager, Idaho Power Company.
 $‐
 $500,000
 $1,000,000
 $1,500,000
 $2,000,000
 $2,500,000
 $3,000,000
 $3,500,000
 $4,000,000
 $4,500,000
2017 2018 2019 2020 2021 2022
CLOUD SEEDING COST BY YEAR
Collabrative Funding Total Cloud Seeding Costs
Linear (Collabrative Funding)Linear (Total Cloud Seeding Costs)

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
REQUEST FOR PRODUCTION NO. 125: Regarding the Company's response to
Production Request No. 6, Attachment G, please provide the date of each transaction.
RESPONSE TO REQUEST FOR PRODUCTION NO. 125: Please see
‘Attachment 1 – Response to Staff Request No. 125’, column G for the transaction dates
associated with the detail provided in the Company’s response to Production Request
No. 6, Attachment G.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
REQUEST FOR PRODUCTION NO. 126: Regarding the Company's response to
Production Request No. 13, Confidential Attachment, please provide jurisdictional
allocations of all expenses.
RESPONSE TO REQUEST FOR PRODUCTION NO. 126: The FERC Accounts
listed in the Company's response to Production Request No. 13, Confidential Attachment
and the Idaho jurisdictional allocation of those accounts is provided in the table below.
Dama es Idaho Allocation % from JSS 107000 * 108000 95.62%** 560000 95.91% 571000 95.91% 580000 95.28% 584000 98.50% 586000 96.77% 588000 95.28%
593000 92.88%
901000 95.01%
921000 95.64% 925000 95.64%

In uries Idaho Allocation % from JSS
925000 95.64%
*Account 107 is construction work-in-progress (“CWIP”), which is not included in
rate base. **Account 108 is Accumulated Provision for Depreciation of Electric Plant in Service.
Without the workorder level detail, these charges cannot be identified to a specific
plant account. Therefore, the percent provided represents the Idaho portion of total
ccumulated Depreciation.

The response to this Request is sponsored by Kelley Noe, Regulatory Consultant,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
REQUEST FOR PRODUCTION NO. 127: The Company states in response to
Production Request No. 15 that "additional advertisements are provided that do not have
above the line charges." Please identify which advertisements are above the line and
which are below the line.
RESPONSE TO REQUEST FOR PRODUCTION NO. 127: Every advertising
charge listed in "Attachment 1 – Response to Staff Request No. 15 Finance Details 2021-
2023 Ads.xlsx" is an above the line charge. However, while 930100 is above the line, all
advertising charges to this account are removed entirely from the rate case request.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
REQUEST FOR PRODUCTION NO. 128: Please indicate which advertisements
from the Company's attachments to its response to Production Request No. 15 correlate
to each expense indicated the Company's response to Production Request No. 14,
Confidential Attachment, on all applicable expenses.
RESPONSE TO REQUEST FOR PRODUCTION NO. 128: Please see
“Attachment – Response to Staff Request No. 128” for a correlation of charges as seen
in column AB. Each applicable entry corresponds to a PDF page number or file provided
with the original response to Request No. 15. Please note that while 930100 is above
the line, all advertising charges to this account are removed entirely from the rate case
request.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
REQUEST FOR PRODUCTION NO. 129: Regarding the Company' s response to
Production Request No. 16, Attachment 1, please provide jurisdictional allocations of all
expenses.
RESPONSE TO REQUEST FOR PRODUCTION NO. 129: The FERC Accounts
listed in the Company's response to Production Request No. 16, Attachment 1 and the
Idaho jurisdictional allocation of those accounts is provided in the table below.
ccount Idaho Allocation % from JSS
571000 95.91%
593000 92.88%
903000 96.72%
908000 97.36%
909000 96.77%
921000 95.64%
923000 95.64%
930100 0%

The response to this Request is sponsored by Kelley Noe, Regulatory Consultant,
Idaho Power Company. 
REQUEST FOR PRODUCTION NO. 130: Regarding the Company's response to
Production Request No. 21, Attachment 1, please indicate which compensation
categories are being sought for recovery.
RESPONSE TO REQUEST FOR PRODUCTION NO. 130: The officer
compensation categories for which the Company is seeking recovery in this case include
Idaho Power’s allocable share of base salary 401(k) matching and certain portions of the
long-term incentive plan related to officer retention. While it was the Company’s intent to
exclude all officer at-risk incentive pay from its request in this case, during the preparation
of this response, it came to light that the 2023 forecast of officer compensation includes
certain long-term officer at-risk incentive pay in the form of restricted stock tied to
the Company’s financial performance. More specifically, the historical actual annual
labor amounts used as the basis to grow year-to-date (“YTD”) February 2023 labor
amounts to year-end 2023 included all long-term officer incentive amounts. As a result,
the 2023 labor cost forecast indirectly includes certain long-term officer incentive
amounts tied to financial metrics, even though the YTD February 2023 labor costs
included only the intended officer base salary and 401(k) categories. Because the
costs associated with these officer incentive categories were included in the rate
request in this case, the Company is prepared to work with Staff to develop an
appropriate course of action in response.
No short-term incentive compensation for officers has been included for recovery
in this case. Further, the Company did not include any officer compensation amounts
charged to IDACORP or IDACORP Financial in its rate case request. Additionally,
IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 20
approximately 25% of the SVP of Public Affairs compensation is not included in the rate
case request.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company. 

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 21
REQUEST FOR PRODUCTION NO. 131: Regarding the Company's response to
Production Request No. 21, Attachment 1, please explain how allocation factors are
determined. Please also provide Jurisdictional allocations.
RESPONSE TO REQUEST FOR PRODUCTION NO. 131: The basis for the
allocation between Idaho Power, IDACORP, and Idaho Financial Services is actual labor
entry related to work performed for each entity.
The FERC Accounts associated with the labor costs provided in the Company’s
response to Production Request No. 21, Attachment 1 and the Idaho jurisdictional
allocation of those accounts is provided in the table below.
Accoun Idaho Allocation % from JSS
107000 CWIP not included in GRC
417420 ccount not included in the GRC
417430 ccount not included in the GRC
417446 ccount not included in the GRC
426400 ccount not included in the GRC
500001 95.92%
500002 95.92%
500003 95.92%
535000 95.90%
539000 95.92%
560000 95.91%
571000 95.91%
580000 95.28%
593000 92.88%
901000 95.01%
920000 95.64%
The response to this Request is sponsored by Kelley Noe, Regulatory Consultant,
Forecasting and Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 22
REQUEST FOR PRODUCTION NO. 132: Regarding the Company’s response to
Production Request No. 24, with the General Wage Adjustment (“GWA”) and every six
months Merit Salary Increases, (“MSI”), are employees eligible for three periodic base
salary increases per year? Please indicate if there is a maximum percentage for GWA
and MSI and explain how increase percentages are determined.
RESPONSE TO REQUEST FOR PRODUCTION NO. 132: As mentioned in the
Company’s response to Production Request No. 24, all employees are eligible for the
annual General Wage Adjustment (“GWA”), if an adjustment is approved by the Board of
Directors. Only employees who are still progressing to the top of their pay grade (median
of market) are eligible for Merit Salary Increases (“MSI”) every six months until they reach
top of grade. Although this percentage varies based on turnover, most employees (64
percent) are only eligible for one increase per year, the GWA.
GWA
The GWA percentage is determined annually by the Board of Directors based on
a number of factors, including salary increase survey data, peer utility union contract
increases, Consumer Pricing Index (“CPI”) and other local economic factors. There is not
a maximum percentage of increase defined for the GWA, but the percentage has
averaged 3.4 percent and ranged from 2-6 percent from 2011 to 2023.
MSI
There are currently 772 employees (36 percent of total employee population) still
progressing through their paygrade. These employees are eligible for a potential MSI
every six months until they reach the top of the pay grade (median of market) for each
role. Employees eligible for an MSI may receive a wage adjustment between 0.0 percent

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 23
and a maximum of 3.8 percent (two-steps) according to the applicable grade and step for
each position. MSI’s are intended to be merit-based compensation increases reflecting
both technical and behavioral performance and progress, not just the passage of time. –
The response to this Request is sponsored by Sarah Griffin, VP Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 24
REQUEST FOR PRODUCTION NO. 133: Regarding the Company’s response to
Production Request No. 25, Confidential Attachment, please explain why the Company
chooses to have a cliff vesting schedule for the 401k plan that fully vests at one year of
service.
RESPONSE TO REQUEST FOR PRODUCTION NO. 133: Idaho Power’s
retirement program offering consists of a defined benefit pension plan with a five-year cliff
vesting period and a defined contribution 401k plan with company matching contributions
subject to a one-year vesting period.
The IRS has requirements related to vesting schedules for defined contribution
retirement plans (401k). All employee contributions to the plan must vest immediately.
Employer contribution vesting must be managed according to the official plan document
and must meet minimum IRS vesting requirements: 100 percent cliff vesting by three
years of service or graded vesting with 100 percent vested by six years of service (20
percent after two years, 40 percent after three, 60 percent after four, 80 percent after five
and 100 percent after six). The IRS vesting requirements have changed over time and
the Company continuously monitors changes to ensure our plan document is compliant.
As with all of Idaho Power’s total rewards offerings, the Company relies on survey
benchmarking and peer comparisons to ensure that plan offerings and design are
competitive. The most recent data from the Willis Towers Watson Benefits Plan Design
Practices Survey provided the following statistics:
Of the 73 utility company respondents, representing 107 defined contribution
plans, 55 percent have an immediate vesting of matching contributions, 26 percent have
a cliff vesting schedule and 18.7 percent have a graded vesting schedule. Of the 28 plans

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 25
with a cliff vesting schedule, the average years to vesting is 2.11 and the median is 2.5.
Considering that over half of the plans vest immediately, Idaho Power’s determined that
one-year cliff vesting is prudent and competitive.
Additionally, Idaho Power also reviewed the publicly filed 401k plan documents for
several northwest peer utilities and determined that a one-year cliff vesting for employer
matching contributions is competitive. NV Energy and Northwestern offer immediate
vesting for employer contributions, Avista has a one-year cliff vesting and PacifiCorp has
a graded vesting schedule with 20 percent vested at one year and 100 percent vested
after five years.
The response to this Request is sponsored by Sarah Griffin, VP Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 26
REQUEST FOR PRODUCTION NO. 134: Regarding the Company's response to
Production Request No. 32, Confidential Attachment 1, please provide transaction level
details for Company purchase cards posted on the dates selected in the attached
spreadsheet "Idaho Power Credit Card Sample" in 2022. This should include date, vendor
names, dollar amount of each transaction, description of purchases, and all other useful
information.
RESPONSE TO REQUEST FOR PRODUCTION NO. 134: Please see
‘Attachment – Response to Staff Request No. 134.’ This detail includes transactions that
were recorded to accounts that were not included in the rate case request or were
removed from the 2022 base financial information, as described in Paula Jeppsen Exhibit
No. 23, Pages 4-9.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 27
DATED at Boise, Idaho, this 8th 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 FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 28
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 8th day of August 2023, I served a true and correct
copy of Idaho Power Company’s Response to the Fifth 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 FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 29
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 FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 30
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 FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 31
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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NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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Stacy Gust, Regulatory Administrative
Assistant