20230814IPC to Staff 120 Supplemental.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

August 14, 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 Supplemental
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:cd
Enclosures
RECEIVED
Monday, August 14, 2023 2:03:56 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S SUPPLEMENTAL 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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CASE NO. IPC-E-23-11

IDAHO POWER COMPANY’S
SUPPLEMENTAL 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 supplements the following information:

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 2
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.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 120:
Please see the fifteen attachments provided for this request.
In addition to the class cost-of-service (“CCOS”) model workpapers, Idaho Power
has included a comparison of allocation factors derived from 2023 test year and 2022
normalized load statistics, attachment 15. Specifically, the energy, demand, and customer
count load statistic-informed allocation factors.
The Company highlights two modifications were required to incorporate
normalized 2022 load statistics into the cost-of-service model:
1) Idaho Power aligned with Staff that 2022 billing determinants would not be
developed as part of this response due to the time requirement to develop and
their use being specific to rate design development, not cost assignment to
customer classes. However, one allocation factor, E99, is derived from an
energy billing determinant, thus Idaho Power utilized 2022 energy load
statistics instead in place of updated billing determinants. The underlying basis
for 2022 energy load statistics is the same as the billing determinants, however,
load statistics are calendar month values while billing determinants are
transformed from calendar month data to billing month data. There is likely an
immaterial difference in each class’s share of energy load statistics versus each
class’s share of energy billing determinates. Finally, the cost category assigned

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 3
by E99 is approximately $2.1 million out of a total of $1.1 billion in expenses,
further reducing the cost-assignment impact of any difference in energy statistic
utilized.
2) The Black Mesa Solar Photovoltaic project was not online in 2022. Micron’s
cost assignment from 2022 data reflects Idaho Power meeting 100 percent of
Micron’s energy requirement consistent with structure of the Micron Special
Contract renewable resource billing construct terms. A commensurate
adjustment was required to Micron’s 2023 revenue forecast to show 100
percent of Micron’s energy sales were provided by Idaho Power’s pooled
system resources in 2022.
Finally, the Company clarifies that it interprets the “Test Year Sales Forecast”
noted in Response to Request for Production No. 118, to be the same as the 2022 load
statistics Idaho Power has utilized in development of the 2022 CCOS model and provided
as an attachment to this response.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 4
DATED at Boise, Idaho, this 14th 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 SUPPLEMENTAL RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 5
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 14th day of August 2023, I served a true and
correct copy of Idaho Power Company’s Supplemental 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 SUPPLEMENTAL RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 6
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 SUPPLEMENTAL RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 7
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 SUPPLEMENTAL RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 8
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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Christy Davenport
Legal Administrative Assistant