20230822IPC to Staff 210-225.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

August 21, 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
Ninth Production Request of the Commission Staff to Idaho Power Company. Although
Production Request No. 216 referenced language from a confidential document provided
in response to Production Request No. 60, Idaho Power believes the language in
Production Request No. 216 should be designated as public information.

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
2023 AUGUST 21, 2023 4:52PM
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. 210, 211, and 225,
to Idaho Power Company’s Response to the Ninth Production Request of the
Commission Staff dated August 21, 2023, contain information that Idaho Power Company
and a third party claim are trade secrets, business records of a private enterprise required
by law to be submitted to or inspected by a public agency, and/or public records exempt
from disclosure by state or federal law (material nonpublic information under U.S.
Securities and Exchange Commission Regulation FD) 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 21st day of August, 2023.
LISA D. NORDSTROM
Counsel for Idaho Power Company

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

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

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

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 210: Please outline the main use for the
Hawk Substation and provide costs to date. In your response, please include a list of
asset(s), the cost of the asset(s), the costs of additional work performed, completion date,
and how much is included in the general rate case.
RESPONSE TO REQUEST FOR PRODUCTION NO. 210: The Hawk substation
is located at 15550 S. Cloverdale Road, Kuna, near the Northeast corner of Cloverdale
Road and Kuna-Mora Road. It is a 138-kV-34.5-kV distribution substation that is serving
the east Kuna area with two new 34.5-kV distribution feeders, HAWK-41 and HAWK-
42. The new Hawk substation service area was required due to growth in the area. The
additional power source offloaded the taxed MORA-42 feeder, allowing the Mora
substation to serve customer growth farther north on Cloverdale Road. In addition, a new
large load customer of Idaho Power’s, who is funding a portion of the substation,
requested service in this area.
See Confidential Attachment – Response to Staff Request No. 210 for the Hawk
substation costs that have closed to plant as of June 30, 2023. The Contributions in Aid
of Construction, or amounts paid by the Company’s large load customer, are reflected in
rows identified as 411 or 412. Please note, although the substation is in service, not all
costs have closed to the work orders and therefore the amounts presented may not reflect
final substation costs. Idaho Power anticipates approximately $125,000 of additional
costs will be recorded associated with the Hawk substation. Work order number
27599341 was the only work order in service in 2022 therefore the only amounts
specifically associated with the Hawk substation included in the Company’s request in
this case.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 3
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 211: For Micron's expansion and its new
fabrication building, please provide a list of projects that are needed to support them, the
cost of the work to date, and where it is included in the general rate case. Please include
a list of projects/workorders that might include, but are not limited to, substations,
distribution lines, and transmission lines.
RESPONSE TO REQUEST FOR PRODUCTION NO. 211: The following are the
work orders associated with Micron’s expansion for which amounts have closed to plant-
in-service as of July 31, 2023:
 27616527 - TEMPORARY RELOCATE 69KV LINE (T210) FOR MICRON
 27618486 - T410 TEMP RELOCATE AROUND WASTEWATER TREATMENT
FACILITY
 27616520 - TEMPORARY RELOCATE 34.5KV FOR MICRON
 27614932 - RELOCATE BOBN 041 PER MICRON REQUEST
 27618475 - CHIP230001 EASEMENT FOR SUBSTATION
 27498265 - RTSN180001- REPLACE YARD LOAD CENTER
See Confidential Attachment – Response to Staff Request No. 211 for the Micron
expansion costs that have closed to plant as of July 31, 2023. The Contributions in Aid of
Construction, or amounts paid by Micron, are reflected in rows identified as 411 or 412.
Please note, not all costs associated with the expansion have closed to the work orders
and therefore the amounts presented do not reflect final costs. Work order numbers
27616527, 27618486, 27616520, and 27614932, totaling negative $67,052, were the only
amounts specifically associated with the Micron expansion included in the Company’s
request in this case.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 5
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 212: Please provide an update to the timeline
for the new distribution/inventory warehouse that is located near the amity substation,
and include when it will be in-use and operational. Also include the costs to date and how
much is included in the general rate case.
RESPONSE TO REQUEST FOR PRODUCTION NO. 212: The new distribution
center is under construction and on schedule to be in-use and operational on December
1, 2023. Total costs to date are $11,068,560 of the $17,695,340 included in the general
rate case request.
The response to this Request is sponsored by Debra Leithauser, Vice President
of Corporate Services and Communications, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 213: Please describe why and who pays for
the relocation of Company facilities that may conflict with road construction.
RESPONSE TO REQUEST FOR PRODUCTION NO. 213: In accordance with
Idaho Code § 62-705, Commission Order Nos. 32476 and 32592, and as stated within
Section 10 of Rule H of the Company’s tariff,
If a Public Road Agency determines that the Company’s facilities
incommode the public use of any road, highway, or street, the Public
Road Agency can require the company to relocate or remove the
facilities. If a Public Road Agency determines that the Company’s
facilities must be relocated or removed because they incommode the
public use of the road, highway, or street, the Company will relocate
its distribution facilities from or within the public road rights-of-way
and the Company will bear the costs of such relocation.

If one or more Private Beneficiaries has requested that the
Company’s facilities be relocated or removed, the Company will use
reasonable efforts to recover that portion of the total Relocation or
removal costs attributable to the request from the Private
Beneficiaries. If the Private Beneficiaries dispute the Company’s
calculation of the Private Beneficiaries’ cost responsibility, either the
Company or the affected Private Beneficiaries may initiate a
proceeding to have the Commission establish the reasonableness of
the Company’s calculation of the Relocation or removal cost
responsibility as between the Company and the Private
Beneficiaries.

Additionally, if the Company is requested to relocate facilities not located in the
public right-of-way (e.g., facilities within an easement), the requesting party is financially
responsible for the cost of such relocation work.
The response to this Request is sponsored by Riley Maloney, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 214: Please provide the Company's
justification for the need for the Company to buy and pay for employee housing. In your
response, please include the cost benefit analysis used to make this decision, the location
of housing, the original cost of housing, the depreciation rate, how many employees will
benefit, and where the associated expenses are located in the general rate case.
RESPONSE TO REQUEST FOR PRODUCTION NO. 214: In consultation with
Staff, Idaho Power has requested an extension for this response and will deliver it on, or
before, August 28, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 215: Regarding Company's response to
Production Request No. 60 - Confidential Attachment 1, please explain if all insurance
expenses provided in the Attachment are all wildfire-related. If not, please provide only
wildfire-related insurance expenses in Excel format by year and provide all invoices and
supporting documentation for 2019 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 215: As described in the
Company’s request for deferral of wildfire mitigation and insurance costs in cases IPC-E-
21-02 and IPC-E-22-27, which the Commission fully authorized in June 2021 and
February 2023, respectively, insurance companies do not and will not—with the exception
of the $1 million “wildfire load” charge—specifically calculate the additional portion of the
Company’s insurance premiums related to wildfire risk. However, Idaho Power’s broker
and insurance companies have explained that increases in insurance premiums have
recently been driven by prior losses incurred and increased risks of losses by insurers
from catastrophes and natural disasters, specifically wildfires in the west. As a result, it is
not possible to specifically identify the dollar amount of premium increases associated
with wildfire risk. However, the Company assesses that wildfire is a key contributor to
rising insurance costs.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 216: Regarding Company's response to
Production Request No. 60, not all the invoices/documentation were provided. Please
provide invoices/documentation for all the expenses listed on Confidential Attachment 1,
including all invoices/documentation from Higgins & Rutledge Insurance, Saif
Corporation, and Ceridian Tax Service.
a. Please explain what "ValmyMonthly","Boardman Monthly"and "Bridger Prop
& Gen Liab" mean, and where each are referenced in the invoices provided; and
b. If supporting documentation or invoices for the expenses mentioned above have
not been provided, please provide them.
RESPONSE TO REQUEST FOR PRODUCTION NO. 216: In consultation with
Staff, Idaho Power has requested an extension for this response and will deliver it on, or
before, August 28, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 11
REQUEST FOR PRODUCTION NO. 217: Regarding the Company's response to
Production Request No. 64, Confidential Attachment 1, please provide all transactions,
invoices, contracts, and backup documents, associated with each transaction in the
attached Confidential spreadsheet "Idaho Power Wildfire Transaction list."
RESPONSE TO REQUEST FOR PRODUCTION NO. 217: In consultation with
Staff, Idaho Power has requested an extension for this response and will deliver it on, or
before, August 28, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 12
REQUEST FOR PRODUCTION NO. 218: In the Company's response to
Production Request No. 73, the Company stated that "[t]he Company conducted a
random sample and only performed audits on 15 percent of the work performed in wildfire
risk zones. In 2023, the Company plans to complete audits of 100 percent of vegetation
work performed in wildfire risk zones." Please explain why the Company is shifting from
15% vegetation audits in 2022 to 100% vegetation audits in 2023.
RESPONSE TO REQUEST FOR PRODUCTION NO. 218: The results of the
random sample plan in 2022 did not show a level of quality of vegetation management
work up to the Company’s standards. As a result, in 2023, the Company is returning to
its original goal of conducting audits of 100 percent of vegetation management work in
wildfire risk zones to ensure reasonable quality of contracted services.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 13
REQUEST FOR PRODUCTION NO. 219: As supplement to the Company's
response to Production Request No. 67, please provide any documentation of each
approved grant (i.e., letter, award, email, etc.). Please explain when the Company was
notified that it had received each grant.
RESPONSE TO REQUEST FOR PRODUCTION NO. 219: In October 2022, Idaho
Power was awarded the Energy Resiliency Grant Program Rebate for vegetation
management/artificial intelligence. The contract for this grant was executed on October
17, 2022, and is provided as Attachment 1 to this request. Please note that the grant
award excluded vegetation management pruning work that was proposed in the
Company’s grant application. The removal of pruning work is noted in the contract’s first
attachment -- Funded Equipment/Services Approved Budget and Project Milestones. As
noted in the Company’s Response to Staff Request No. 67, the funds for this grant have
not been received as of August 2023.
The Energy Resiliency Grant Program Rebate for mesh wraps was also awarded
in October 2022, with the contract signed on October 17, 2022. The contract for this
project is provided as Attachment 2 to this request. The funds for this grant were received
in January 2023.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 14
REQUEST FOR PRODUCTION NO. 220: In the Company's response to
Production Request No. 67, Attachment 2, the Company's application for an Office of
Energy and Mineral Resource grant request was $2.65 million for "Pruning" ($2.5 million)
and "Vegetation Intelligence"($150,000), for a total project budget of $5.3 million. Please
explain why the Company did not receive the $2.5 million it had requested for additional
pruning to be completed in 2022.
RESPONSE TO REQUEST FOR PRODUCTION NO. 220: The Idaho State Office
of Energy and Mineral Resources (“OEMR”) Energy Resiliency Grant Program had limited
funding and was a competitive application process with other entities seeking funds. As
determined by OEMR, Idaho Power received a smaller grant than was requested in the
Company’s application.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 15
REQUEST FOR PRODUCTION NO. 221: Please reconcile Idaho jurisdictional
Wildfire Mitigation Plan ("WMP")-related expenses in 2022 of $21,003,203 from Jeppsen
Direct Testimony at 13 to the 2022 Idaho jurisdictional WMP-related expenses listed in
the "Confidential Attachment - Response to Staff Request No. 63".
RESPONSE TO REQUEST FOR PRODUCTION NO. 221: “Confidential
Attachment – Response to Staff Request No. 63” columns D through F are Idaho
jurisdictional incremental expenditures and columns H through J are total O&M
expenditures. The 2022 Idaho jurisdictional WMP-related expenses are reconciled
between Jeppsen Direct Testimony at 13 to “Confidential Attachment – Response to Staff
Request No. 63” column E.
Please see table below.
($000s) 2022
Request No. 63 Incremental O&M Expenditures $15,074
Insurance Deferred 6,923
Depreciation Deferred 158
Communication/Alert Tool development - 2022 Expense not
deferred until 2023 (81)
Total System Incremental $22,075 Idaho Jurisdictional Split (weighted average of WMP expense
accounts) 95.15%

Idaho Deferral (referenced in Jeppsen Direct Testimony at 13) $21,003

The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 16
REQUEST FOR PRODUCTION NO. 222: Please explain the difference in the
estimated incremental expenses of vegetation management for 2023 to 2025 from
Version 5 of the WMP to the Company's response to Production Request No. 103.
RESPONSE TO REQUEST FOR PRODUCTION NO. 222: At the close of 2022,
the Company identified that shortages of qualified contract vegetation management
workers in the Company’s service area would require Idaho Power to hire traveling crews
from other parts of the country at premium costs. In addition, inflationary pressure on fuel,
as well as tools and equipment, resulted in higher costs than were previously estimated.
Even with additional resources secured in 2022, actual production output was below
anticipated levels due to turnover and less of an ability to utilize mechanized equipment
than originally planned.
Based on the experience from 2022, the cost forecast for 2023 – 2025 was revised
to reflect new estimates that would account for new resources necessary to fully transition
to a three-year pruning cycle by the end of 2025 while annually accomplishing the
enhanced vegetation management activities listed in the WMP.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 17
REQUEST FOR PRODUCTION NO. 223: Please provide the yearly Capital and
O&M expenses for each notification system provided in "Attachment 2 - Response to Staff
Request No. 106".
RESPONSE TO REQUEST FOR PRODUCTION NO. 223: Please see Attachment
1 – Response to Staff Request No. 223, with the following notes:
 Maintenance costs do not include internal labor costs related to supporting the
outage communication systems, as the Company does not currently track the
number of support hours dedicated to this function.
 Outage Alert Development and Implementation capital costs include in-progress
communication enhancements that have not yet been implemented (expected
implementation of November 2023).
 For EONS capital and operations and maintenance (“O&M”) costs, please see the
Company’s response to Staff Request No. 105 (Attachment 1 – Response to Staff
Request No. 105).
 For outage alert push notifications through Idaho Power’s mobile app, please see
the Company’s response to Staff Request No. 92 for capital and O&M costs for
the mobile app (Attachment 1 – Response to Staff Request No. 92b).
 For the Automated Dialer System maintenance costs, the outbound dialer system
is a component of the overarching customer service interaction system. The dialer
cannot function on its own without the full system operational. As 30 percent of
the interaction system ports are used for the dialer, the cost was calculated as 30
percent of the cost to maintain the full interaction system. The outbound dialer is
used for other notification types outside of planned outages, such as collection

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 18
calls.
 For the SMS and Email Twilio maintenance costs, there are many types of
outbound communication conducted through these channels outside of outage
alerts. The costs provided are for the full functionality of the services and not
specific to outage communication notifications.
 The Outage Map Notifications services costs include the costs for Google
mapping services, as the notification functionality on the map would not exist
without the Google mapping services.
The response to this Request is sponsored by Bo Hanchey, Vice President of
Customer Operations and Chief Safety Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 19
REQUEST FOR PRODUCTION NO. 224: For the Company's Enterprise Omni-
Channel Notification System ("EONS") tool, please explain if the tool could replace the
other alert notification systems. If not, please explain why. If yes, please explain why the
Company has not shifted to using EONS as the main notification tool.
RESPONSE TO REQUEST FOR PRODUCTION NO. 224: Idaho Power’s seeks
to provide the lowest-cost customer communication tools that meet defined requirements,
including functionality, security, compliance, and timeline considerations. Consolidating
technology often provides cost efficiencies related to licensing and support and is,
therefore, assessed as a preferred option when selecting and designing solutions.
In the case of outage communication, Idaho Power needs to be able to
communicate with customers both in response to an outage event that has occurred and
in advance of emergency and/or unplanned events (e.g., Public Safety Power Shutoff
(“PSPS”), load shed, etc.). None of the Company’s current systems meet all these needs
as they either do not contain the information needed to support these processes or they
do not provide the functionality to manage the associated communication steps and
content.
Idaho Power will re-evaluate the potential to consolidate its communication
systems when it prepares to replace its Outage Management System (leveraged to trigger
Outage Alerts) and its Customer Interaction Center (leveraged for Planned Outage
communication) as well as when making enhancements to EONS (leveraged for PSPS
and load shed notifications) to eliminate manual steps and increase speed of message
delivery. This could involve leveraging additional services offered by Message Broadcast
(the EONS vendor), incorporating EONS functionality as part of one of the

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 20
aforementioned replacement projects, or internally developing a consolidated solution.
This decision will be driven by comparing the total cost, customer experience, and time
to deliver each of the identified options.
The response to this Request is sponsored by Bo Hanchey, Vice President of
Customer Operations and Chief Safety Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 21
REQUEST FOR PRODUCTION NO. 225: Version 4 and Version 5 of the
Company's WMP estimated incremental expenses for each component of the WMP in
2022 and 2023. Please explain why the Company did not have any expenses for certain
components of the WMP in "Confidential Attachment - Response to Staff Request No.
63".
RESPONSE TO REQUEST FOR PRODUCTION NO. 225: Please see the
Confidential Attachment – Response to Staff Request No. 225 for a table that provides
wildfire mitigation-related operation and maintenance expenditures through June 2023.
Details for each category with zero expenditures shown in the table are provided below:
 Weather Forecasting - System development and support – The
development of a new weather forecasting system that leverages an
ensemble of weather forecasts is underway. Hardware quotes and software
scoping were performed in late 2022, which delayed the start of
development until 2023.
 Pole Loading Modeling & Assessment (Contract service) – The
identification of a preferred contractor and scoping extended this project into
2023 without any expenditures to date. Ground-based LiDAR surveys and
structural load analysis are expected to begin later in 2023.
 Wildfire Detection Cameras – The Company is working with camera
vendors to determine optimal tower locations with viewsheds that overlap
with Idaho Power’s infrastructure. This work involves analyzing tower
locations, power, and communication requirements, and gaining permits.
Collaboration with local, federal, and state fire agencies has taken place to

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 22
develop plans for fire response which has resulted in feedback on how to
setup a notification system and processes. Throughout the course of this
work, the Company has learned that camera installation is more complex
than anticipated and, in some cases, requires a full engineering assessment
of towers. The Company has also found other camera vendors that have
come onto the market recently and as a result, a Request for Information
event was held in July and August 2023 to help determine preferred
suppliers for the pilot. While these challenges have delayed the installation
of wildfire detection cameras, the Company is striving to have cameras
installed later this year.
 Tools/Equipment/ Mobile Weather Kits for Field Observers – For purposes
of reporting and tracking, the Company combined expenditures associated
with fire-specific mitigation tools (e.g., on-truck water pumping equipment,
fire extinguishers, shovels) with mobile weather kits for Field Observers.
Through June, the Company has no expenditures due to reusing existing
tools and the timing associated with evaluating additional need for on-the-
ground weather instrumentation for Field Observers.
 Environmental Management Practices – This category is used for costs
associated with applying for right-of-way permitting for the use of ground
sterilant around poles. For 2022 through June 2023, there have been no
costs associated with permitting for the application of sterilant in targeted
pole locations within wildfire risk zones.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 23
 International Wildfire Risk Mitigation Consortium (“IWRMC”) – The
Company officially joined the IWRMC in early 2023 and expects the
membership dues to be paid in August 2023. Project work involving wildfire
mitigation technology and the development of a Public Safety Power Shutoff
Plan in 2022 delayed Idaho Power’s membership until 2023. Since May
2023, the Company has been an active participant in monthly meetings and
webinars as part of the IWRMC membership.
 Transmission Thermography Inspection Mitigation - Red Risk Zones – The
Company carries out thermography inspections on transmission lines in
wildfire risk zones annually. The inspections have not identified heating
issues that require mitigation in 2022 through June 2023.
 Distribution Thermography Inspection Mitigation - Red Risk Zones - The
Company started carrying out thermography inspections on distribution
lines in red risk zones in 2022. These inspections have not identified heating
issues that require mitigation through June 2023.
 Transmission Wood Pole Fire Resistant Wraps - Red Risk Zone – The
installation of mesh wrap on transmission poles in red risk zones was
completed in 2022, resulting in no costs for this work in 2023.
 Enhanced Practices for Distribution Red & Yellow Risk Zones (Pre-Fire
Season Patrols/Mitigation, Pole Clearing, Removals, Work QA) –
Confidential Attachment – Response to Staff Request No. 225 provides
expenses for enhanced practices.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 24
 Fuel Reduction Program – This program involves coordination with federal
and state fire agencies, landowners, local fire departments, and county
emergency managers. The Company is actively working with the National
Forest Foundation to finalize a contract to begin fuel reduction work along
Idaho Power facilities in the Boise National Forest later this year. Progress
was delayed due to the coordination required to plan and scope the project
with the different stakeholders.
 Communication/Alert Tool development (System set up, outage maps,
critical facilities identification)/Communication/Alert Tool for Public Safety
Power Shutoff (“PSPS”) Customer Alerts/Extended Use — For purposes of
reporting and tracking, the Company combined expenditures associated the
Communication/Alert Tools development and PSPS customer alerts.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 25
DATED at Boise, Idaho, this 21st 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 CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 26
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 21st day of August 2023, I served a true and
correct copy of Idaho Power Company’s Confidential Response to the Ninth 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 CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 27
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 CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 28
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 CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 29
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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Walmart Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
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Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
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Stacy Gust, Regulatory Administrative
Assistant